Resource Efficient Use of Mixed Wastes Improving management-KH0517212ENN (001-058) PDF

Resource Efficient Use of Mixed
Wastes
Improving management of
construction and demolition waste
Final report
October 2017
EUROPEAN COMMISSION
Directorate-General for Environment
European Commission
B-1049 Brussels
EUROPEAN COMMISSION
Resource Efficient Use of Mixed Wastes

Improving management of construction and demolition waste
Final report
EUROPE DIRECT is a service to help you find answers
to your questions about the European Union
Freephone number (*):
00 800 6 7 8 9 10 11
(* ) T he information given is free, as are mos t c alls (though s ome operators , phone boxes or hotels may c harge you )
LEGAL NOTICE
This document has been prepared for the European Commission however it reflects the views only of the
authors, and the Commission cannot be held responsible for any use which may be made of the information
contained therein.
More information on the European Union is available on the Internet (http://www.europa.eu).
Luxembourg: Publications Office of the European Union, 2017
PDF ISBN 978-92-79-76478-3 doi:10.2779/99903 KH-05-17-212-EN-N
© European Union, 2017

Reproduction is authorised provided the source is acknowledged.
Resource Efficient Use of Mixed Wastes
Improving management of construction and
demolition waste
Final report
October 2017
In association with :
Table of Contents
1. INTRODUCTION _______________________________________________________________________ 6
1.1. Context _________________________________________________________________________________ 6
1.2. Objectives of the study ____________________________________________________________________ 7
1.3. Presentation and methodology of the different tasks ___________________________________________ 8
1.3.1. Task 1: Diagnosis of the situation as regards CDW management in EU Member States _____________ 8
1.3.2. Task 2: Case studies _________________________________________________________________ 8
1.3.3. Task 3: Identification of good practices ___________________________________________________ 8
1.3.4. Task 4: Assessment of the reliability of CDW statistics _______________________________________ 9
1.3.5. Task 5: Preparation and organisation of a workshop ________________________________________ 10
1.4. Structure of this report ___________________________________________________________________ 10
2. CDW MANAGEMENT PERFORMANCE IN EU-28 MEMBER STATES _________________________________ 11

2.1. Introduction ____________________________________________________________________________ 11
2.1.1. CDW classification in EU statistics ______________________________________________________ 11
2.1.2. Data quality ________________________________________________________________________ 11
2.2. CDW generation performance _____________________________________________________________ 12
2.2.1. Key performance indicators – CDW generation tends to be related to the economic situation of the
MS _______________________________________________________________________________ 12
2.2.2. Nature of CDW generated – A major fraction of mineral waste ________________________________ 14
2.3. CDW treatment performance, distance to 2020 target and forecasts ______________________________ 15
2.3.1. CDW treatment performance – A relative importance of recovery compared to landfilling/backfilling for
all Member States ___________________________________________________________________ 15
2.3.2. Distance to 2020 target – A target already reached by 9 Member States ________________________ 21
2.3.3. Forecasts – An analysis that depends widely on the inclusion of backfilling ______________________ 23
2.4. Focus on hazardous waste ________________________________________________________________ 24
2.4.1. Hazardous waste generation – CDW, a major share in hazardous waste amounts ________________ 24
2.4.2. Hazardous waste treatment – A concentration of treatment facilities in a selection of Member States __ 28
2.5. Focus on backfilling______________________________________________________________________ 30
2.5.1. Definition of “backfilling” – A Eurostat guidance that tends to clarify the WFD definition _____________ 30
2.5.2. Potential modification of the definition of “backfilling” introduced by the Circular Economy Package –
A risk of considering the production of recycled aggregates as backfilling _______________________ 31
2.5.3. Inclusion of backfilling in the EU 2020 target – A disputable statement toward high quality recycling ___ 31
2.5.4. Interpretation and reporting of backfilling by MS – Various practices among Member States _________ 37
3. PLAUSIBILITY OF OFFICIAL CDW STATISTICS ________________________________________________ 39

3.1. CDW data quality in EU MS – Further improvements needed in most Member States________________ 39
3.2. Good methodological practices – Recommendations to enhance data quality and harmonise MS
methodologies __________________________________________________________________________ 42
3.3. Statistical treatment of specific materials/practices – Observed discrepancies among Member States _ 43
3.3.1. Naturally occurring material defined in category 17 05 04 in the list of waste (Soil) ________________ 43
3.3.2. Mineral waste from construction and demolition (W121) _____________________________________ 43
3.3.3. Backfilling _________________________________________________________________________ 44
3.3.4. End of Waste (EoW) criteria ___________________________________________________________ 45
3.3.5. On-site recycled waste _______________________________________________________________ 45
3.3.6. Hazardous Waste ___________________________________________________________________ 45
4. CDW MANAGEMENT PRACTICES IN THE MS _________________________________________________ 47
Resource Efficient Use of Mixed Wastes – Improving management of construction and demolition waste – Final report 2
4.1. Member States practices: main legislative, regulatory and structural differences observed __________ 47
4.1.1. Legal and regulatory framework – Different levels of maturity across the EU _____________________ 47
4.1.2. Enforcement of legislation – A logical impact on CDW recovery performance ____________________ 50
4.1.3. Regulatory and other non-legislative requirements / practices – Different tools helping MS in their
CDW management __________________________________________________________________ 51
4.1.4. Treatment capacity – A significant number of Member States lacking treatment capacity ___________ 54
4.2. Lessons learned from the case studies ______________________________________________________ 56
4.3. Evaluation of good practices and factors that support improved CDW management performance ____ 58
4.3.1. Waste prevention ___________________________________________________________________ 59
4.3.2. Reuse ____________________________________________________________________________ 62
4.3.3. Recycling/recovery __________________________________________________________________ 65
4.3.4. Use of reclaimed and recycled content ___________________________________________________ 70
4.3.5. Focus on end-of-waste criteria _________________________________________________________ 74
4.3.6. Focus on Green Public Procurement (GPP) _______________________________________________ 77
4.3.7. Other measures ____________________________________________________________________ 80
5. REGIONAL DIFFERENCES IN CDW MANAGEMENT PERFORMANCE FOR SELECTED MS ___________________ 81

5.1. The UK and its regions ___________________________________________________________________ 82
5.2. Spain and its regions _____________________________________________________________________ 87
5.3. Belgium and its Regions __________________________________________________________________ 92
5.4. Key success factors – A need for national consistency ________________________________________ 96
6. RECOMMENDATIONS FOR IMPROVING CDW MANAGEMENT IN MS ________________________________ 100

6.1. Measure to manage _____________________________________________________________________ 100
6.2. Target waste prevention _________________________________________________________________ 102
6.3. Refocus on reuse _______________________________________________________________________ 104
6.4. Keep it clean (source segregation) ________________________________________________________ 105
6.5. Remove the backfilling barrier ____________________________________________________________ 107
6.6. Products, not waste _____________________________________________________________________ 108
6.7. GPP: lead by example ___________________________________________________________________ 109
6.8. Enforce to reinforce _____________________________________________________________________ 110
6.9. Continuous and holistic improvement ______________________________________________________ 111
7. PRIORITISATION OF THE RECOMMENDATIONS AND POTENTIAL IMPACT OF THE MAIN MEASURES ___________ 114
7.1. Prioritisation of the recommendations _____________________________________________________ 114
7.2. Environmental and socio-economic benefits and impacts of the most promising measures _________ 123
7.2.1. Include in the WFD a 70% recycling target for CDW to be met by 2030 ________________________ 123
7.2.2. Pre-demolition and renovation audits and selective demolition _______________________________ 128
8. APPENDICES ______________________________________________________________________ 135

8.1. Appendix A – EWC_Stat and ELoW codes __________________________________________________ 135
8.2. Appendix B – CDW management maturity matrix ____________________________________________ 138
8.3. Appendix C – Summary sheets of the six selected case studies ________________________________ 140
8.3.1. Democles ________________________________________________________________________ 140
8.3.2. Gypsum to Gypsum ________________________________________________________________ 141
8.3.3. Olympics games construction works ___________________________________________________ 142
8.3.4. Estonian Recycling Competence Centre ________________________________________________ 143
8.3.5. Pilot project of a mechanical treatment plant for C&D inert waste _____________________________ 144
8.3.6. ZenRobotics ______________________________________________________________________ 145
8.4. Appendix D – Country snapshots _________________________________________________________ 147
8.4.1. Austria ___________________________________________________________________________ 147
8.4.2. Belgium __________________________________________________________________________ 148
8.4.3. Bulgaria __________________________________________________________________________ 150
8.4.4. Croatia __________________________________________________________________________ 151
8.4.5. Cyprus ___________________________________________________________________________ 152
8.4.6. Czech Republic ____________________________________________________________________ 153
8.4.7. Denmark _________________________________________________________________________ 154
8.4.8. Estonia __________________________________________________________________________ 156
8.4.9. Finland __________________________________________________________________________ 158
8.4.10. France ___________________________________________________________________________ 159
8.4.11. Germany _________________________________________________________________________ 161
8.4.12. Greece __________________________________________________________________________ 162
8.4.13. Hungary _________________________________________________________________________ 164
8.4.14. Ireland ___________________________________________________________________________ 165
8.4.15. Italy _____________________________________________________________________________ 166
8.4.16. Latvia ___________________________________________________________________________ 168
8.4.17. Lithuania _________________________________________________________________________ 169
8.4.18. Luxembourg ______________________________________________________________________ 170
8.4.19. Malta ____________________________________________________________________________ 172
8.4.20. Poland ___________________________________________________________________________ 173
8.4.21. Portugal __________________________________________________________________________ 174
8.4.22. Romania _________________________________________________________________________ 176
8.4.23. Slovakia _________________________________________________________________________ 177
8.4.24. Slovenia _________________________________________________________________________ 178
8.4.25. Spain ____________________________________________________________________________ 179
8.4.26. Sweden __________________________________________________________________________ 181
8.4.27. The Netherlands ___________________________________________________________________ 182
8.4.28. United Kingdom ___________________________________________________________________ 184
8.5. Appendix E – Regional analysis ___________________________________________________________ 186
8.6. Appendix F – Prioritisation of the recommendations (medium and low potential benefits) __________ 207
List of figures
Figure 1: Diversity of CDW per activity ........................................................................................................................... 6
Figure 2: Mtonnes of CDW generated, 2012 ..................................................................................................................... 12
Figure 3: Tonnes of waste generated/€Million turnover, 2012........................................................................................... 13
Figure 4: Breakdown of total generated waste in 2012 ..................................................................................................... 14
Figure 5: Breakdown of CDW generated by material type ................................................................................................ 15
Figure 6: Total CDW treated as % total CDW generated .................................................................................................. 16
Figure 7: Waste management summary ........................................................................................................................... 17
Figure 8: Waste management routes for ‘Concrete, brick, tiles and ceramics’ (17 01) ..................................................... 18
Figure 9: Share of CDW landfilled and disposal costs ...................................................................................................... 19
Figure 10: Proportion of national aggregate demand met by recycled aggregate ............................................................. 20
Figure 11: CDW recovery rates reported by MS in compliance with the Waste Framework Directive. The 70% target is
shown in black................................................................................................................................................................... 21
Figure 12: 2012 CDW recovery rates calculated in compliance with the WFD using all the available national information
provided in Task 1 of this study ......................................................................................................................................... 22
Figure 13 : 2012 CDW recovery rates calculated in compliance with the WFD using all the available national information
provided in Task 1 of this study, excluding backfilling ....................................................................................................... 23
Figure 14: Model outputs for overall waste flows (generation, treatment, recycling and landfilling) for the
baseline and the more ambitious scenarios (EU28) .................................................................................................... 24
Figure 15: Hazardous CDW generated per €Million turnover, 2012 .................................................................................. 26
Figure 16: Breakdown of CDW generated, 2012 ............................................................................................................... 26
Figure 17: Breakdown of hazardous waste generated in 2012 ......................................................................................... 27
Figure 18: Breakdown of treated waste ............................................................................................................................. 28
Figure 19: Share of each treatment operation compared to the total amount of hazardous mineral CDW treated in EU
Member States for the year 2012 ...................................................................................................................................... 29
Figure 20: % Hazardous CDW recovered ......................................................................................................................... 29
Figure 21 : Reclamation of excavated areas (in construction) - earthworks ...................................................................... 34
Figure 22: Reclamation of excavated areas: restoration of a mine (before and after) ....................................................... 34
Figure 23: Reclamation of excavated areas:filling in a quarry void ................................................................................... 34
Figure 24: Landscape engineering: an example of a noise bund/barrier ........................................................................... 35
Figure 25: Covering landfills: capping of a landfill ............................................................................................................. 35
Figure 26: Spatial distribution of the overall data quality in the EU in 2012 ....................................................................... 40
Figure 27: The amount of CDW backfilled (from Eurostat) – ref. Report 3.1 .................................................................... 44
Figure 28: Level of maturity of legal framework in MS ...................................................................................................... 50
Figure 29: Management practices for sustainable CDW ................................................................................................... 53
Figure 30: Treatment capacity in EU-28 Member States .................................................................................................. 55
Figure 31: Uptake of all EU GPP in the EU27 (last contracts by numbers) (CEPS, 2012) ................................................ 79
Figure 32: Backfilling (% of generated CDW), Eurostat, 2012......................................................................................... 123
Figure 33: Schematic representation of the baseline scenario and the alternative scenario ........................................... 126
List of tables
Table 1: MS colour coding – data quality level .................................................................................................................. 12
Table 2: CDW generated in 2012 by the 28 EU MS .......................................................................................................... 12
Table 3: Summary of waste generated KPIs ..................................................................................................................... 14
Table 4: Level of confidence in data quality ...................................................................................................................... 22
Table 5: CDW suitable for backfilling ................................................................................................................................ 31
Table 6: Backfilling activities and their likelihood of compliance with the WFD criteria, and their environmental risk ........ 32
Table 7: Examples of applications for processed and unprocessed inert mineral CDW ................................................... 35
Table 8: Checklist to establish if an activity can be considered as backfilling ................................................................... 36
Table 9: Levels of overall CDW data quality in 2012 (MS are classified by alphabetical order in each category) ............. 39
Table 10: Summary of all types of issues impacting the CDW data quality and associated examples ............................. 41
Table 11: Summary of factors influencing CDW management .......................................................................................... 51
Table 12: Presentation of the selected case studies for Task 2 ........................................................................................ 56
Table 13: Initial Maturity matrix overall results .................................................................................................................. 59
Table 14: Examples of barriers for waste prevention ........................................................................................................ 60
Table 15: Examples of drivers for waste prevention .......................................................................................................... 60
Table 16: Maturity matrix levels related to waste prevention ............................................................................................. 61
Table 17: Member State maturity matrix performance for waste prevention ..................................................................... 61
Table 18: Best and worst country performers for relevant KPIs ........................................................................................ 62
Table 19: Examples of barriers to reuse ........................................................................................................................... 63
Table 20: Examples of drivers for reuse ............................................................................................................................ 63
Table 21: Maturity matrix levels related to recycling and recovery ................................................................................... 68
Table 22: Member State initial maturity matrix performance for recycling and recovery ................................................... 68
Table 23: Country KPI performance for CDW ................................................................................................................... 69
Table 24: Examples of barriers to the incorporation of reclaimed and recycled content listed by interviewed stakeholders
.......................................................................................................................................................................................... 70
Table 25: Examples of drivers for the incorporation of reclaimed and recycled content listed by interviewed stakeholders
.......................................................................................................................................................................................... 71
Table 26: Maturity matrix levels related to incorporation of reclaimed and recycled content ............................................. 73
Table 27: Member State maturity matrix performance for incorporation of reclaimed and recycled content ..................... 73
Table 28: Summary of main drivers and barriers regarding the EoW concept .................................................................. 76
Table 29: Construction key environment impacts relevant to materials efficiency and recommended GPP ..................... 78
Table 30: Overall framework for CDW activities for the selected Member States ............................................................. 82
Table 31: Recommended Data improvements to support best practices ........................................................................ 101
Table 32: Waste prevention related recommendations ................................................................................................... 102
Table 33: Reuse recommendations ................................................................................................................................ 104
Table 34: Source segregation recommendations ............................................................................................................ 106
Table 35: Recommendations to move from waste into products ..................................................................................... 108
Table 36: GPP recommendations ................................................................................................................................... 109
Table 37: Enforcement recommendations....................................................................................................................... 110
Table 38: Matrix overall results –initial ............................................................................................................................ 112
Table 39 : Ranking of the recommendations with high potential benefits ........................................................................ 115
Table 40: Waste types (EWC-Stat codes) considered in the CDW target calculation suggested definition ......... 135
Table 41: CDW Legislation and policies for UK Regions ............................................................................................... 186
Table 42: CDW Legislation and policies for Spain and selected Regions ...................................................................... 193
Table 43: CDW Legislation and policies for Belgium Regions........................................................................................ 200
1. Introduction
1.1. Context
Construction and demolition waste (CDW) is the left-over material from construction, refurbishment as well
as road and building demolition. It is a mix of different material including inert waste, non-inert non-
hazardous waste and hazardous waste.
Due to the diversity of CDW produced per activity, these activities each face different challenges and may
develop various management practices accordingly. The two main sectors are the public works, including the
road construction sector, and the building sector. While the public works sector has widely developed the
use of recycled aggregates in most MS, the building sector is facing major issues mostly due to the diversity
of material involved as well as the diversity of building and construction sites in terms of managed quantities
and material characteristics. Indeed, CDW generated in the building sector includes a large variety of waste,
especially when looking into the finished work waste as well as hazardous waste.
Figure 1 below illustrates the diversity of CDW:
Figure 1: Diversity of CDW per activity
Note: soils are excluded from the WFD definition of CDW but may be included by some MS in their national legislation
CDW is the most significant waste stream in the EU, accounting for over 800 million tonnes per year
(including soil). As shown in Figure 1, it consists of various material, including concrete, bricks, gypsum,
wood, glass, metals, plastic, solvents, hazardous substances (asbestos, PCBs, etc.) and excavated soil,
many of which can be recycled. CDW arises from activities such as the construction of buildings and civil
infrastructure, total or partial demolition of buildings and civil infrastructure, road construction and
maintenance.
CDW has received more and more attention in the past few years as it is a lens to understanding the
potential for resource efficiency improvement in the construction sector. Indeed, CDW has a high potential
for re-use and recycling, since some of its components have a high resource value and/or can be readily
recycled. In particular, there is a market for aggregates derived from CDW in roads, drainage and other
construction projects. But the recycling potential of CDW is still under-used. Moreover, recovery
performances between EU Member States (MS) differ significantly from one MS to another (from 10% to
over 95%). MS with the lowest performances can certainly improve by applying good practices implemented
by those achieving the highest performances.
The potential to increase the resource efficiency of the construction sector by improving the CDW recycling
rate is significant but identifying and transferring good practices is not an easy task. In fact, the practical
management of CDW varies greatly across MS (due to local variations in context, legislation, enforcement,
and construction practices). Moreover, monitoring and data collection of recycling performance are often not
accurate, due to data traceability and availability issues. Monitoring MS performances in recycling CDW is a
real challenge that MS and European authorities are facing. It is however an essential step in assessing MS
progress with regards to their recovery targets. Finally, different definitions of CDW are applied throughout
the EU, which makes cross-country comparisons difficult.
In view of the importance of this waste stream, the lack of comprehensive information regarding the situation
in Member States and some uncertainty linked to official CDW statistics made it necessary to perform an in-
depth analysis of the situation, identifying best practices, as well as key factors to achieve a sustainable
management of CDW and formulating recommendations for action.
1.2. Objectives of the study
This study was initiated in January 2015, led by Deloitte in partnership with BRE, ICEDD, VTT, RPS and
FCT of NOVA University of Lisbon. It aims at investigating the current CDW management situation in EU
Member States, identifying obstacles to recycling and potential deficiencies that could lead to non-
compliance with EU waste legislation. Good practices in terms of creating conditions for increasing CDW
recycling and for improving the quality of recycling and recovery were identified and a set of
recommendations to address potential barriers was formulated. In parallel, success stories of efficient CDW
management were showcased in 6 case studies, illustrating key elements for success, as well as any
necessary preconditions. Finally, the credibility of official CDW statistics was assessed, identifying sources of
inaccuracy and proposing measures for improvement.
The main objectives of this project were defined by the European Commission and are as follows:
 Analyse the current CDW management situation in Member States "on the ground", against national
(and/or regional, where appropriate) waste management plans and waste prevention programmes,
identifying obstacles to recycling and identifying potential shortfalls in CDW management practices in
Member States that could lead to non-compliance with EU waste legislation, in particular the waste
hierarchy and the recovery target for CDW established in Article 11 of the Waste Framework
Directive.
 Perform six case studies of entities (regions, municipalities and companies) with a good record as
regards to CDW management, explaining why they can be regarded as success stories and
highlighting their main key elements that contributed to their success, as well as the necessary
preconditions.
 Identify good practices in terms of creating conditions for increasing CDW recycling rates and for
improving the quality of recycling and recovery and formulating a set of recommendations to address
the shortfalls observed in those Member States (MS) where management of CDW raises some
concerns.
 Assess the plausibility of official CDW statistics, identifying sources of inaccuracy, identifying best
practices regarding statistics in Member States or regions and formulating recommendations to
ensure that CDW can be effectively traced and that statistics duly reflect the actual waste raisings.
For an effective fulfilment of the abovementioned objectives, the work carried out was broken down into four
tasks as well as a workshop held in May 2016:
 Task 1: Diagnosis of the situation as regards CDW management in EU Member States, including the
distance to the target defined in Article 11 of the Waste Framework Directive;
 Task 2: Case studies;
 Task 3: Identification of good practices related to creating conditions for a sustainable management
of CDW;
 Task 4: Assessment of the reliability of CDW statistics, including plausibility checks. Proposals for
the improvement of CDW statistics;
 Task 5: Preparation and organisation of a workshop.
1.3. Presentation and methodology of the different tasks
1.3.1. Task 1: Diagnosis of the situation as regards CDW management in EU

Member States
The main objective of Task 1 was to collect detailed information concerning CDW management in the 28 MS,
focusing both on practical and legal points of view as well as on recycling and recovery performances. This
objective was fulfilled thanks to a thorough screening phase. This task also aimed at giving a preliminary
insight on performance and practices (practical and legal), and at identifying potential barriers and drivers,
especially towards reaching the 2020 recovery target. It was thus a very important first step, laying the
ground for further analysis on specific topics in CDW management practices in MS.
In order to analyse the performance and management practices of CDW in the 28 MS, a comprehensive
methodology was set up, to facilitate the gathering of relevant data and information from each individual MS.
Firstly, a set of criteria was established in order to have a solid and even basis for analysis of all MS.
Secondly, based on the analysis criteria, MS screening factsheets were prepared, including a structured
presentation of relevant information and data. The process of data gathering included in-depth literature
analysis and stakeholder consultation.
The result of the screening of the MS included 28 comprehensive country factsheets, presenting a detailed
current situation in CDW management. The full set of country factsheets is available on the webpage of the
study (see Section 1.4: Structure of this report).
1.3.2. Task 2: Case studies
Task 2 of the project consisted in performing six case studies: these case studies were selected among
initiatives that were identified during Task 1. The objective was to present case studies at different levels,
from regions, municipalities to companies. These case studies aimed at highlighting barriers and drivers for a
CDW sustainable management across the EU. Importance was given to the potential for replicability and
innovation in order to identify opportunities for developing similar initiatives in other MS.
The main challenge of this task was the identification of relevant success stories. Their usefulness depends
on their diversity but also on their potential for replicability and sustainability (economic, technical, social and
environmental aspects). Furthermore, as a quality assessment of these success stories depends on
available information, the selection of the case studies also depended on our access to information and
willingness of the corresponding actors to share data and feedback. Therefore, actors were involved at the
very beginning of the project to maximise their participation and our ability to access the required
information.
The six case studies selected were:
 Democles (France)
 Gypsum to Gypsum (EU)
 London 2012 Summer Olympics (UK)
 Estonian Recycling Competence Centre (Estonia)
 Mechanical treatment plant for inert C&D waste in Buzau County (Romania)
 ZenRobotics Recyclers (Finland)
Six detailed case studies resulted from the analysis of the selected initiatives. These are available on the
webpage of the study (see Section 1.4: Structure of this report).
1.3.3. Task 3: Identification of good practices
The objective of Task 3 was to analyse MS performance in terms of managing CDW and identifying good
practices relating to the types of intervention and implementation across the EU.
This task included 5 subtasks, as described below:
 Task 3.1: Analysis of Member States performance
CDW performance can be measured in various ways, the most obvious being in relation to the EU
target to recycle or recover at least 70% of CDW. Other quantitative criteria have also been
assessed to identify any trends and to examine performance from different angles. This was built
upon the information collected during tasks 1 and 2, taking into account results from Task 4
regarding the quality of reported statistics.
 Task 3.2: Analysis of regional differences
Three Member States were selected to undertake a regional analysis, in terms of performance in
managing CDW. These were Belgium, UK and Spain. The purpose of this analysis was to consider
key influencing factors and their impact on CDW management, such as population density,
economic status, policy variation, tax measures, etc. Information from country reports from Task 1
were supplemented with additional data sources and stakeholder engagement as available to make
the assessment.
 Task 3.3: Analysis of good practices
Each Member State has implemented various types of intervention with the objective of improving
CDW management. There is great variation in terms of the types and quantities of interventions, how
rigorously they are implemented and the level of impact they are having across the EU. A key part of
task 3 was to gain insights into the extent to which specific types of intervention are having a positive
impact, and investigate the framework of conditions upon which they might depend upon for
success. Through undertaking this evaluation of interventions across the EU, it was expected that
the recipe(s) for success would become clearer; i.e. to be able to determine correlations between
specific types of intervention assessed in Task 3.3 and the performance measured in Task 3.1. The
information was mainly derived from the country reports from Task 1, with cross-referencing to the
performance measured in Task 3.1. Some specific measures (End of Waste Criteria and Green
Public Procurement) were assessed using the information from the country reports prepared during
Task 1 and external data sources.
 Task 3.4: Analysis of backfilling practices
This task focussed on the assessment of whether and under which circumstances backfilling can be
considered a genuine and environmentally sound recovery operation in the context of the WFD 70%
recovery target for CDW. This was built upon data provided in the country reports from Task 1 and
the Eurostat statistics validated in Task 4.
 Task 3.5: Conclusions and recommendations
The recommendations were built upon interim reports from Task 3.1 to 3.4, as well as additional data
sources and perspectives from BRE resource efficiency expertise to create a set of key
recommendations.
The detailed findings of subtasks 3.1 to 3.5 are presented in five separate reports to which was added
information gathered during the workshop (see Task 5 below). These specific reports are available on the
webpage of the study (see Section 1.4: Structure of this report).
1.3.4. Task 4: Assessment of the reliability of CDW statistics
Statistical reliability is of outmost importance to ensure the validity and precision of any kind of analysis on
CDW and hence for policymaking. The aim of task 4 was to assess the reliability of CDW data, by assessing
the quality of MS official CDW data, by analysing the production process of CDW data (the way MS
administration collect and report CDW data), and by looking at important changes that might affect the data
quality in the near future, in particular with regards to comparability of CDW data across MS, as well as in
terms of consistency of time series.
More specifically, the objectives of task 4 were to:
 Classify MS in terms of their CDW data quality level, based on a country by country analysis.
 Present the main methodologies used by MS to collect the data, assess and classify MS in terms of
data collection methodologies, highlight the lessons learned from the less mature and best practices
in methodologies used, and consider relatively new concepts such as backfilling and the end-of-
waste status on the Eurostat statistics.
 Summarise the main problems highlighted in the Eurostat data, with a focus on hazardous waste.
 Summarise the main findings that arise from the comparison of Eurostat statistics with detailed
national data, particularly on the extent to which the official CDW definition is representative or not of
CDW generated and treated in MS.
 Present the available information on the current distance to target (set in the Waste Framework
Directive) and forecasted CDW amounts in the future, using an update of the existing CDW model
developed in 2015.
In order to perform the assessment of the data quality in the European Member States, a methodology was
set up to come up with a non-subjective quotation of data quality for each Member State. This methodology
consisted of producing, for each Member State, a separate report that analysed the different aspects of their
data quality based on qualitative assessments of their data collection methodologies and comparisons with
other data sources and quantitative assessments of their Eurostat data quality. These qualitative and
quantitative assessments were summarised for each Member State according to a quotation system.
The separate reports for each Member State were sent to the national statistical offices (NSO) in charge of
transmitting the data to Eurostat to get their feedback on analyses performed and to gather valuable
information on issues that were still pending after the analyses. In total, only 6 countries did not answer the
questions sent, which shows the very important implication of Member States on the topic of C&D waste.
The international organisations FIR, FEAD, and EDA also gave their feedback via a conference call.
The information and findings of Task 4 are detailed in a specific report, into which was included the
information gathered during the workshop. This specific report is available on the webpage of the study (see
Section 1.4: Structure of this report).
1.3.5. Task 5: Preparation and organisation of a workshop
A one day workshop was held the 25 May 2016 at the premises of the European Commission in Brussels.
This workshop had two key objectives:
 Discuss the findings of the study and share best practices.
 Carry out an open exchange of views with the aim of achieving a good understanding of barriers and
opportunities, and the measures, tools and steps to take in order to address barriers and realise
opportunities. It should also be considered how European legislation and funds could be used to
improve the situation in the Member States.
In order to meet the aforementioned objectives, two forms of exchanges were proposed:
 A plenary session to present the preliminary findings of the study;
 Six thematic breakout sessions to enable exchanges of views between participants around six key
issues identified in the study and discuss possible solutions at European level: EU targets,
prevention, demolition practices, reuse, recycled materials market, data collection practices: how to
improve reporting.
All information gathered from the presentations and the breakout sessions are recorded in a dedicated
report, which is available on the webpage of the study (see Section 1.4: Structure of this report), as well as
the presentations made during the workshop.
1.4. Structure of this report
This report presents the main findings of the study and aims at giving a global picture of the current situation
as regard as CDW management practices and performances across the EU. It is structured as follows:
 Section 2 gives an overview of the performance of the 28 MS in terms of CDW management with
three focus on regional differences, hazardous waste and backfilling;
 Section 3 presents the main results of the analysis of CDW statistics including the identification of
good practices to enhance data quality as well as some details on the statistical treatment of specific
materials and practices;
 Section 4 focuses on CDW management practices in EU-28 MS and presents an evaluation of good
practices as well as the success factors for improved CDW management;
 Section 5 concludes this report with a synthesis of the main drivers and barriers to resource
efficiency in CDW management and the main recommendations for improving CDW management
based on the work of the study.
As mentioned above, all deliverables of tasks 1 to 5 may be downloaded from the webpage for the study:
http://ec.europa.eu/environment/waste/studies/mixed_waste.htm
2. CDW management performance
in EU-28 Member States
2.1. Introduction
2.1.1. CDW classification in EU statistics
Different waste streams and waste categories are used by Member States for the compilation of CDW data.
European Waste Catalogue (EWC-Stat) classification
Eurostat data referred to in this study is data on waste generation, treatment and treatment infrastructure
and waste collection coverage pursuant to Regulation No 2150/20021. This data is available for all Member
States in the same format. It is similar and publicly available on the Eurostat website2. Eurostat waste
statistics are available at the three digit level of the European Waste Catalogue3 (EWC_Stat), which is a
mainly material-based classification of waste. The EWC_Stat codes do not include information regarding the
waste generating activity, except for some EWC_Stat codes such as W121, which specifically refers to
mineral waste from construction and demolition. Yet Eurostat data on generation are reported by the
countries according to different NACE activities4. This means that EWC-Stat data does not allow the
identification with certainty whether waste originates from construction and demolition activities, except for
waste generated and reported under the construction sector (NACE F). It would however be an
underestimation to only consider wastes reported in NACE F, as Member States are known to also report
generated CDW in other sectors than the construction sector. Therefore a proxy was used to calculate the
amounts of CDW generated in each Member State. This proxy is based on the method for calculating the
target for CDW set out in Appendix III of the Commission Decision 2011/753/EU5 (more details on the
EWC_Stat codes included in the proxy are presented in Appendix A).
European List of Waste (ELoW) classification
The Waste Framework Directive6 (WFD – 2008/98/EC) stipulates that the 70% CDW recovery objective must
be calculated based on the European List of Waste (LoW) classification. In addition to the waste composition
(LoW contains 17 codes for the different types of CDW), this classification also allows to track the activities
generating this waste (the entire list of 17 codes and corresponding EWC-Stat codes are presented is
Appendix A).
The facts and figures presented in section 2 of this report are based either on EWC_Stat or LoW codes,
depending on the best available data. Sources for the data used are always indicated.
1
EC, Regulation (EC) No 2150/2002 of the European Parliament and of the Council of 25 November 2002 on Waste Statistics, 2002
<http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:02002R2150-20101018&from=EN> [accessed 26 February 2015].
2
http://ec.europa.eu/eurostat/data/database
3
See Appendix I of EC, Regulation (EC) No 2150/2002 of the European Parliament and of the Council of 25 November 2002 on Waste
Statistics.
4
Statistical classification of economic activities in the European Community (NACE Rev.2), see
http://ec.europa.eu/eurostat/documents/3859598/5902521/KS-RA-07-015-EN.PDF
5
EC, Commission Decision of 18 November 2011 Establishing Rules and Calculation Methods for Verifying Compliance with the
Targets Set in Article 11(2) of Directive 2008/98/EC of the European Parliament and of the Council, 2011 <http://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=celex%3A32011D0753>.
6
EC, Directive 2008/98/EC of the European Parliament and of the Council of 19 November 2008 on Waste and Repealing Certain
Directives.
2.1.2. Data quality
Although this report provides a quantification of the performance for Member States, the results should be
viewed while keeping the data quality in mind. Until all MS have a similar level of data quality, it will be
difficult to carry out a quantitative comparison of MS performance and have confidence in the trends that
may, or may not, be seen in the charts given in this report.
As part of Task 4 (CDW statistics cross-country analysis: results and recommendations, section 1.2), data
has been reviewed for each MS, scored out of 5 and given a quality level of poor, modest or good. Where
possible, the results showing the MS performance have been presented as figures and have been colour-
coded according to the MS CDW data quality score, as shown in Table 1.
Table 1: MS colour coding – data quality level
CDW data quality score Data Quality level Colour used in charts
Between 1.5 and 2.5 Poor Grey
Between 2.6 and 3.6 Modest Yellow
Greater than 3.6 Good Green
2.2. CDW generation performance
2.2.1. Key performance indicators – CDW generation tends to be related to the

economic situation of the MS
In 2012, the 28 Member States generated around 830 Mtonnes of CDW, including 480 Mtonnes of soil and
dredging spoil.
Hence, excluding soil and dredging spoil, the 28 MS generated around 350 Mtonnes of CDW in 2012. Table
2 below shows a breakdown by type of waste.
Table 2: CDW generated in 2012 by the 28 EU MS
Inert waste (Mt) 315

Non-inert non-hazardous waste (Mt) 26
Hazardous waste (Mt) 10
Total CDW excluding soil and dredging spoil (Mt) 351
As can be seen, inert waste represents 90% of total generated CDW.

Figure 2 below presents the amount of CDW generated by the 28 Member States. Unsurprisingly, large
countries generate the most CDW.
90
80
70
60
Millions of tonnes
50
40
30
20
10
-
DE FR UK IT ES NL FI BE AT PL HU CZ DK RO SE PT EL BG LU LT SK MT EE LV HR SI IE CY
Figure 2: Mtonnes of CDW generated, 2012

The amount of CDW generated relative to the construction industry turnover is shown in Figure 3 for each
MS together with the average for the MS with modest or good data quality (i.e. those with poor data quality
have been excluded from the average figure). The data relates to waste generated and turnover for 2012
from Eurostat7 (with the exception of the turnover data for Ireland, which dates from 2011 and has been
provided by the country report).
700
600
500
Tonnes/Million Euros
400
300
200 Average, 164
100
Figure 3: Tonnes of waste generated/€Million turnover, 2012
7
Eurostat data 2012, Annual company statistics for special aggregates of activities, [sbs_na_sca_r2], Turnover or gross premiums
written for NACE_R2 =F (Construction)
Note: For this analysis, Eurostat data for 2012 was used and the CDW definition includes W061, W062, W063, W071,
W074, W075 from NACE F and W121 across all NACE activities. As requested by the EC, W077 and W12B from NACE
F were also added.
There is a very large variation in the CDW generated related to the turnover of the construction
sector (in € Million). Setting aside MS with poor data quality (in grey), Germany, Hungary and the
Netherlands produce significantly more CDW than the average (above 300 tonnes/million euros) and
Portugal and Slovenia produce very small amounts (around 20 tonnes/million euros). There is no clear
explanation for these differences. Assuming that the cost to build the same building in a wealthier country
(compared to less economically advanced countries) are higher because of the higher labour costs, this
should lead to lower KPIs when comparing CDW versus turnover (in wealthier countries, a lower percentage
of the money spent on construction will be devoted to materials and a higher percentage will be spent on
salaries, compared to countries that are less wealthy). However, the trend for the KPI to be higher (in
Western Europe) reinforces the conclusion that wealthier countries are more wasteful.
Large infrastructure projects have been reported for Germany, Hungary, France, Italy and the UK, which
could account for the relatively large CDW generation. All countries with larger amounts of waste generated
already have national waste prevention plans in place whereas Croatia, Slovenia and Portugal have not
adopted waste prevention plans. This could indicate that where better waste prevention policies are in place,
waste data is better reported.
The relationship between, on the one hand, CDW generated and MS population and, on the other hand,
CDW generated and MS GDP was also examined. It confirmed the analysis of the amount of CDW
generated relative to the construction industry turnover. For those countries where the data quality was
thought to be good, Germany, France, Hungary and the Netherlands are consistently in the top CDW
generators. Those countries producing the smallest amount of CDW include Slovenia, Portugal, Slovakia
and Croatia. The results of waste generated Key Performance Indicators are summarised in Table 3.
Table 3: Summary of waste generated KPIs
Key Performance Indicator Top 5 MS (most waste) Bottom 5 MS (least waste)
CDW/€Million turnover Germany, Hungary, Netherlands, Slovenia, Portugal, Croatia, Slovakia,

Spain, France Poland
CDW/person Netherlands, Luxembourg, Croatia, Slovenia, Portugal, Slovakia,

Germany, France, Austria Poland
CDW/GDP Netherlands, Hungary, Germany, Slovenia, Portugal, Slovakia, Croatia,

France, Estonia Denmark
2.2.2. Nature of CDW generated – A major fraction of mineral waste
European statistics do not permit a break-down of CDW by activity (construction, refurbishment, demolition),
or by subsector (public works, buildings), and too few information could be retrieved at MS level to perform
an estimate.
However, the data available provides a break-down of the material included in CDW: the majority of CDW
generated in Member States is composed of mineral waste from construction and demolition (W121) as
shown in Figure 4.
100%
90%
80%
70%
W12B
60%
W121
50% W077
40% W075
W074
30%
W071
20% W063
10% W062
W061
0%
Latvia
Finland
Slovakia
Estonia
Bulgaria
Hungary
Belgium
Romania
Croatia
Poland
Sweden
Spain
Lithuania
Malta
France
Slovenia
Cyprus
Netherlands
Germany
Italy
Ireland
Austria
Czech Republic
Portugal
Greece
United Kingdom
Denmark
Luxembourg
Figure 4: Breakdown of total generated waste in 2012
Note: W061 = ferrous metallic waste; W062 = non-ferrous metallic waste; W063 = mixed ferrous and non-ferrous metallic
waste; W071 = glass waste; W074 = plastic waste; W075 = wood waste; W077 = waste containing PCBs; W12B = Other
mineral waste (excl. C&D waste, combustion waste, soils, dredging spoils, waste from waste treatment); W121 = mineral
waste from construction and demolition
When trying to go deeper into details regarding the breakdown by material type, data is only available for
selected MS (Germany, Denmark, Estonia, Croatia, Hungary, Luxembourg, Portugal, Slovakia). A
breakdown of the materials in CDW for these MS was based on the EWC top level categories (17 01, 17 02
etc.) These are shown in Figure 6 as a percentage of the total CDW generated (excluding soils, 17 05).
100%
17 09, Other construction and
90% demolition wastes
80% 17 08, Gypsum-based construction

material
70%
60% 17 06, Insulation materials and

asbestos-containing construction
50% materials
17 04, Metals (including their alloys)
40%
30%
17 03, Bituminous mixtures, coal tar
and tarred products
20%
10% 17 02, Wood, glass and plastic
0%
17 01, Concrete, bricks, tiles and
ceramics
Figure 5: Breakdown of CDW generated by material type

This high level breakdown of materials for a limited number of MS shows a high degree of variability and
surprising results. This shows that for most MS the major waste types are concrete, bricks, tiles and
ceramics, which is consistent with the fact that the major fraction of CDW generated in Member States is
composed of inert waste. But it seems unlikely that any MS would have more metal-based waste being
generated than concrete and brick based waste, as this seems to be the case in Estonia, Croatia and
Slovakia. In this regard, it is to be noted that the figures shown here are higher than those reported in official
data. For Croatia, the national data is based only on that provided by the waste producers whereas the data
provided to Eurostat pursuant Regulation (EC) No 2150/2002 (referred hereafter as WStatR) is an
amalgamation of data from producers/collectors and treatment companies. For Slovakia and Estonia the
national metal data includes all chapter 17 codes whereas the official data only includes metals from NACE
F.
In addition, this indicates that for Malta, the CDW is poorly defined with the majority being classified as
‘Other construction and demolition waste’.
One conclusion that could be drawn is that large amounts of ‘inert’ CDW are not being reported, perhaps
due to very high levels of on-site reuse. If this is happening, the overall waste generation data would be
significantly underestimating the actual amount of CDW that is generated.
2.3. CDW treatment performance, distance to 2020 target and forecasts
2.3.1. CDW treatment performance – A relative importance of recovery compared

to landfilling/backfilling for all Member States
In the manual on waste statistics, it is stated that waste treatment is understood as the generic term for all
recovery and disposal operations including preparatory operations8. The Directive 2008/98/EC (or WFD)9
further defines the following terms:
 Recovery means any operation the main result of which is waste serving a useful purpose by
replacing other materials which would otherwise have been used to fulfil a particular function, or
waste being prepared to fulfil that function, in the plant or in the wider economy.
 Recycling is a subset of recovery and ‘means any recovery operation by which waste materials are
reprocessed into products, materials or substances whether for the original or other purposes.’ It
includes the reprocessing of organic material (e.g. composting, anaerobic digestion etc.) but
excludes the use as fuels and the use for backfilling operations.
 Disposal means any operation which is not recovery even where the operation has, as a secondary
consequence, the reclamation of substances or energy.’
The analysis of the amount of CDW treated compared to the amount of CDW generated is shown in Figure
6. It should be noted that CDW treatment data is only based on W121 code (mineral CDW) whereas the
CDW generated includes other waste codes. This means that a country treating all the CDW it generates
would show a percentage lower than 100 in the figure below.
8
Eurostat, p. 32.
9
EC, Directive 2008/98/EC of the European Parliament and of the Council of 19 November 2008 on Waste and Repealing Certain
Directives, 2008, p. 28 (p. 98) <http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32008L0098> [accessed 25 February 2015].
200
180
160
140
120
100
80 Average, 92.7
60
40
20
Figure 6: Total CDW treated as % total CDW generated

The data indicates that much more CDW is treated than generated in Belgium and Slovenia whereas
Portugal treats just over half of CDW generated (MS with poor data quality were not included in the
analysis).
The amount of CDW imported by Belgium, Slovenia and Ireland was investigated but it was minimal and
would not account for the large amount of CDW treated.
Further information was sought from Belgium to explain the large difference between CDW generated and
CDW treated and, according to OVAM, the public waste agency of the Flemish region, this difference is due
to the fact that a large portion of generated rubble is crushed on-site and not reported as generated but only
as treated.
For Slovenia, the discrepancy between generated and treated CDW is due to several reasons: the collapse
of the construction industry in Slovenia resulted in large amounts of CDW in temporary storage awaiting
treatment. Furthermore, there is inadequate legislation on reporting of CDW. No further information about the
large amount of CDW in temporary storage was available but, after 3 years storage, this waste would be
considered to be illegally landfilled, according to the Landfill Directive.
For Portugal, the difference between generated and treated CDW occurs because a significant number of
businesses report a portion of treated CDW using treatment codes10 that are not covered by the Waste
Statistics Regulation. This was also the case for Poland.
The waste management routes used for CDW across the MS are summarised in Figure 7 below. This is
based on Eurostat data of waste treated in 201211. However, in view of the above considerations about
statistics, these figures have to be used with caution.
10
Codes for transfer/treatment of waste to enable its disposal (D13 – blending, D14 – repackaging and D15 – storage) or codes for
transfer/treatment of waste to enable its recovery (R12 – exchange of waste and R13 – storage of waste prior to recovery)
11
Eurostat data 2012
100
90
80
70
60
% recovered
%
50
40 % backfilled
30 % incinerated
20 % landfilled
10
0
Belgium
Latvia
Estonia
Romania
Hungary
Slovakia
Finland
Bulgaria
Netherlands
Italy
Slovenia
Sweden
Ireland
Lithuania
Germany
Poland
Cyprus
Malta
Austria
Portugal
Spain
Czech Republic
France
Croatia
Luxembourg
Greece
United Kingdom
Denmark
Figure 7: Waste management summary

Figure 7 displays the relative importance of recovery compared to landfilling/backfilling for all Member
States. The percentage of waste landfilled varies from less than 1% (Netherlands) to over 99% (Greece).
Countries with high recovery rates are likely the countries with best practices in terms of CDW
treatment (recycling) and correspond to countries that are classified under good or modest data quality:
 For instance, the Netherlands, Luxembourg and Belgium are densely populated areas, where
great efforts have been put in reducing the disposal of mineral waste from construction and
demolition, more specifically by recycling this waste to produce secondary aggregates that can be
used, among others, for road applications.
 Many of the MS with higher proportions of recovery have a good spread of CDW management
facilities available such as Denmark, Italy, Ireland, Germany and Luxembourg.
 In addition, some MS have landfill bans (or partial bans) in place. For example, the Netherlands
has a landfill ban on recyclables and Belgium has bans in Wallonia and Flanders (ban on landfilling
of mixed CDW). Denmark has a ban on landfilling of waste suitable for incineration, which would
explain the low levels of landfilling and relatively high levels of CDW incineration (5%). Malta has
been using backfilling as the primary treatment method of CDW since 2003 when a ban of CDW
from landfills took place. Until recently, the backfilled amounts of CDW were reported as landfilled.
However, under the light of the possibility of using backfilling as recovery in the calculation of the
WFD target, Malta is considering reporting the entire volume of CDW backfilled in spent quarries as
recovered and would thus reach an extremely high recovery rate (see Figure 12).
Regarding countries with low recovery rates:
 The low amounts of CDW recovered in Greece could be related to the non-existence of an
effective policy for the use of recycled materials as well as the lack of obligations regarding
recycled materials or recycled content in construction materials.
 Finland’s low recovery rate could be due the misallocation of excavated soils in the waste
category mineral waste from construction and demolition, therefore not reflecting the “real” figures
of CDW treatment in the country12.
12
‘ARGUS. Validation and Publication of Waste Statistics - Report on the in-Depth Validation of WStatR Data and Documentation of
Country Specific Results - Reference Year 2010 -’.
 Many MS with low levels of recovery such as Croatia, Estonia and Slovakia have a limited spread
of CDW management facilities.
The amount of CDW that is incinerated is minimal except in Denmark, Sweden and Finland, where there
is a significant use of wood for construction activities. Similarly, the amount of backfilling appears to be
small except for Ireland, Estonia, Poland and the Czech Republic. However, this is likely to be due to the
differences in reporting of backfilling information. For example, Portugal, Denmark and Latvia have not
reported any backfilling as this is wrongly included in the reported data to the EC as landfilling or recovery. In
contrast, Ireland have followed the definition provided in the Commission Decision and Eurostat guidance on
backfilling and have reported approximately 25% of CDW as backfilled.
When focusing on the management routes by material types for concrete, brick, tiles and ceramics as
shown on Figure 8, one may observe that there are differences in how waste was reported with some
countries reporting larger amounts of mixed waste. Improved segregation of materials revealed a strong
trend for higher levels of recovery (as opposed to backfilling or landfilling) compared to MS with high levels of
mixed waste, as shown in Figures 3 and 4. Indeed, source segregation is more likely to occur where there
are legal requirements, such as selective demolition, or economic incentives contributing to lower waste
management costs.
Figure 8: Waste management routes for ‘Concrete, brick, tiles and ceramics’ (17 01)
Disposal costs. Landfill taxes and high disposal costs are often cited as one of the drivers for recovery and
recycling. Therefore, a negative correlation between overall disposal costs and the percentage of CDW
landfilled could be expected. However, analysing the available data, it appears that there is not a clear
correlation between disposal costs and recovery rates, most probably due to the fact that many other factors
may affect the waste route in each MS (see Figure 9 below). In some instances such as the United Kingdom
and the Netherlands, high disposal costs and low rates of landfilling were observed but in other instances
such as Austria and Slovenia the rate of landfilling was low in spite of low disposal costs. For Slovenia, this
could be due to the amount of waste, which is in temporary storage, rather than landfilled.
Figure 9: Share of CDW landfilled and disposal costs13
The weak (negative) correlation can be explained by other factors that also influence the level of landfilling,
such as the actual implementation of a landfill tax and the existence of a suitable network of recycling
infrastructure in all regions.
The landfill tax has been implemented differently in different MS, with some countries having regional
variations or variations for different materials. There are also differences in the way the tax is collected and
spent. The Netherlands, UK and Denmark have all had landfill tax in place for several years and the tax has
increased over time. In all three cases, the tax is thought to have been effective at reducing the levels of
landfilling. In contrast in Bulgaria, the implementation has not been effective due to contradictions between
national law and local implementation. In Portugal, the perception was that the tax had not achieved the
desired effect so changes to the way the tax is implemented have recently been made. The tax now varies
depending on the waste treatment method.
The analysis suggests that the availability of treatment facilities affects the level of landfilling. In Slovakia the
spread of facilities is poor with only 60 recovery facilities, 41 of which are mobile devices and these are
thought to have insufficient capacity for current demand. According to the ZRSM (Association for
construction material recycling development), the high costs of transport are seen as a barrier to using the
recovery facilities and there is a complicated and expensive system of licences and fees in place which
makes on-site recycling complicated.
In contrast, the UK, the Netherlands and Belgium have a good spread of facilities. In Belgium, there are 9
landfills but over 400 recovery facilities and for Austria, there is a dense network of recovery facilities across
the country.
The impact of increasing landfill costs on the illegal management of CDW is not clear. For example, the
landfill tax has been in place for several years in the UK and the levels of illegal fly-tipping in England
increased from 2012 to 2014 although CDW only accounts for about 6% of all instances. However, the
opposite is the case in Germany, which has no landfill tax in place and yet illegal CDW management is not
thought to be a major issue. For Austria and the Netherlands, which have also had a landfill tax in place for
several years, no information was available regarding the level of illegal CDW management but it is thought
that existing enforcement is effective. In Bulgaria, Croatia and Greece the level of enforcement is low and
illegal CDW management is reported to be a problem.
13
Various sources of data, including CEWEP report (available at http://www.cewep.eu/media/www.cewep.eu/org/med_557/1529_2016-
10-10_cewep_-landfill_inctaxesbans.pdf) and country factsheets
Imports and exports. CDW is usually heavy and not very valuable. Therefore, the amounts of CDW
imported and exported generally represented a very small proportion of the total CDW generated. However,
some MS exported a large proportion of hazardous CDW. This was thought to be due to the limited facilities
available within these MS to manage the hazardous CDW generated. The MS that import hazardous CDW
were reported to have sufficient capacity to manage this waste.
The MS exporting the greatest proportion of hazardous CDW are Ireland, Greece and Malta. For all three
MS, the majority of the exports were asbestos containing waste which is exported to Germany or Spain. It
has been reported that these MS do not have sufficient facilities to manage the CDW produced, therefore it
is exported.
There are high levels of hazardous CDW imports to Belgium, Sweden, Germany and the Netherlands. For
Belgium, most imports are from neighbouring countries (France and the Netherlands) with smaller amounts
from Luxembourg. Similarly for the Netherlands, the majority of the imports are from Belgium, Switzerland
and Germany. Some of these imports may be due to the fact that facilities in neighbouring countries are
nearer the construction site. The Netherlands and Germany are both reported to have sufficient or excess
capacity to treat hazardous CDW.
Recycled aggregates. Analyses of the amount of recycled aggregate produced show that this was relatively
small compared to the total aggregate demand: as an average, 9% of the demand for aggregates was
covered with recycled aggregates. This suggests that the market could absorb increasing amounts of
recycled aggregates in most MS. However, it should be noted that the availability of recycled aggregate is
likely to vary over time and regionally with some areas having a shortage of materials while other areas may
have a surplus as highlighted in a German study of long-term potentials of high-grade recycling of mineral
construction waste14. Figure 10 provides an overview of the proportion of national aggregate demand met by
recycled aggregates across MS.
Figure 10: Proportion of national aggregate demand met by recycled aggregate
14
Determining Resource Conservation Potentials in the Recovery of Construction Waste and Formulating Recommendations on Their
Use Schiller et al, Environmental Research of the Federal Ministry of the Environment, Nature Conservation and Nuclear Safety, 2010,
https://www.umweltbundesamt.de/sites/default/files/medien/461/publikationen/texte_56_2010_kurzfassung_e1_0.pdf
2.3.2. Distance to 2020 target – A target already reached by 9 Member States
The Waste Framework Directive (2008/98/EC) includes in Article 11(2) a specific target for the reuse,
recycling and other material recovery of CDW:
‘by 2020, the preparing for re-use, recycling and other material recovery, including backfilling operations
using waste to substitute other materials, of non-hazardous construction and demolition waste excluding
naturally occurring material defined in category 17 05 04 in the list of waste shall be increased to a minimum
of 70 % by weight.’
Member States shall provide data on the state of preparation for reuse, recycling and material recovery of
the respective waste stream either for each year, or for every other year, if data is calculated on the basis of
the Waste Statistics Regulation. The first data under this reporting obligation was due by the end of
September 2013, covering the reference period from 2010 to 2012.
CDW recovery rates calculated in compliance with the Waste Framework Directive were reported by only 22
EU Member States. As shown in Figure 11 below, the following six Member States did not report CDW data
for any of the three reference years: Denmark, Greece, France, Cyprus, the Netherlands and Romania15.
100
90
80
70
60
50
40
30
20
10
0
IE BE DE UK PL LU CZ IT EE LT HR HU ES FI MT SK BG DK EL FR CY LV NL AT PT RO SI SE
2010 2011 2012
Figure 11: CDW recovery rates reported by MS in compliance with the Waste Framework Directive. The 70%
target is shown in black
During the course of this study, additional data was provided by national statistics offices: either detailed
national data with a more detailed breakdown by type of waste or national totals for CDW generated and
treated that can be used to complete the picture provided in Figure 11.
Adjusted recovery rates were therefore calculated based on the best available information that had become
available in the course of this study. The level of confidence of these adjusted recovery rates provided here
depends on the following two factors:
 the method used to calculate the recovery rate (i.e. Eurostat data used for both numerator and
denominator, Eurostat data used only for either the numerator or the denominator or detailed
national data used for both numerator and denominator);
 the quality of the data used.
Confidence levels detailed for each country were obtained by giving a score from 1 to 3 on both methods
and data quality. Each country has received a final confidence score that represents the sum of the data
quality confidence score and the method confidence score and has subsequently been qualified as ‘high
confidence in recovery rate produced’ (scores of 5 and 6), ‘medium confidence in recovery rate produced’
(scores of 3 and 4) and ‘low confidence in recovery rate produced’ (scores of 2).
15
‘ARGUS. Compliance Reporting on Waste Framework Directive - Recycling and Recovery Rates for 2010, 2011 and 2012. Report on
the Validation of Construction and Demolition Waste Data - Draft’.
Table 4: Level of confidence in data quality
Colour used in Figure 12 and Figure
Confidence level
13
Low Grey
Medium Yellow
High Green
100%
90%
80%
70%
60%
50%
40%
30%
20%
10%
0%
MT BE* NL LU* HU AT EE DE ES LT UK CZ* SI* PL FR CY DK IT SK HR SE RO LV PT IE BG FI EL
Figure 12: 2012 CDW recovery rates calculated in compliance with the WFD using all the available national
information provided in Task 1 of this study
Note: for countries indicated by *, i.e. BE, LU, SI and CZ, data are taken without backfilling as recovery rates would
exceed 100% if backfilling was taken into account.
There is a discrepancy between the recovery rates obtained using the methods presented in Figure 11 and
the figures that were officially reported by the MS to the EC for several countries. This illustrates again that
the concepts behind the definition of the recovery rate might be unclear for some countries.
Even if Figure 12 must be interpreted with caution, it shows that 9 MS already achieved the WFD 70% target
(MT, BE, NL, LU, HU, AT, EE, DE, ES) in 2012 and 6 MS were close, with a recovery rate higher than 60%
(LT, UK, CZ, SI, PL, FR).
In some MS (Malta, Spain, Slovakia, Cyprus and Poland), backfilling is a key factor in meeting the EU
recovery target: In these countries, up to 74% of CDW is being backfilled (Malta). It is to be noted that there
are indications that some operations that have been reported as backfilling may not meet the conditions laid
down in EU legislation. The possibility of amending the definition of backfilling in EU legislation with a view to
ensure that backfilling is carried out under environmentally sound conditions is being explored. For countries
that are relying to a large extent on backfilling of CDW to meet the EU recovery target, an amendment of the
backfilling definition after 2020 could have a major impact.
Figure 13 shows the recovery rates for all MS in 2012 excluding backfilling. In this case, only 7 MS would
meet the EU recovery target.
100%
90%
80%
70%
60%
50%
40%
30%
20%
10%
0%
MT BE NL LU HU AT EE DE ES LT UK CZ SI PL FR CY DK IT SK HR SE RO LV PT IE BG FI EL
Figure 13 : 2012 CDW recovery rates calculated in compliance with the WFD using all the available national
information provided in Task 1 of this study, excluding backfilling
2.3.3. Forecasts – An analysis that depends widely on the inclusion of backfilling
A project commissioned by the European Commission to Eunomia Research and Consulting Ltd and
conducted in 2015 required that a construction & demolition (C&D) waste model be developed with several
scenarios included.
The business as usual (baseline) scenario assumes that Member States will not make any effort to
increase their recovery rates, and that the only thing that would change in the future are the amounts of C&D
waste arising. These will indeed keep on growing at a rate defined by the GDP times the growth multiplier,
which is set to 0.5 in wealthier Member States and to 1 in less wealthy Member States. In 2020, it is set to
0.5 for all Member States.
In the more ambitious scenario, backfilling was excluded in the calculations and the minimum target for
2020 was set at 70%.The main reason for excluding backfilling is due to the quality of the current data. Most
countries are not able to correctly estimate backfilling and therefore include backfilling data in recycling data.
The overall increase in waste generated and treated in the EU is the same for both scenarios. The overall
amount of CDW generated (excluding excavated soil) is 356 Mtonnes in 2012 and 385 Mtonnes in 2020. The
increase in the amounts of waste treated follows exactly the same pattern as the model uses the same
hypothesis to generate both numbers. It increases from 296 Mtonnes in 2012 to 320 Mtonnes in 2020.
Figure 14 presents the evolution of recycling and landfilling for both the baseline and the more ambitious
scenario. In 2020, the fixed target for the recovery rate set in the more ambitious scenario induces an
increase of 22 Mtonnes of CDW recycled and a decrease of 13 Mtonnes of CDW sent to landfill.
300000
Overall waste flow - Thousand tonnes

250000
200000
150000
100000
50000
0
2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020
Recycling - baseline Landfilling - baseline

Backfilling - baseline Recycling - Full implementation
Landfilling - Full implementation Backfilling - full implementation
Figure 14: Model outputs for overall waste flows (generation, treatment, recycling and landfilling) for the
baseline and the more ambitious scenarios (EU28)
The exercise presented here stresses the importance of quality input data. The quality of the output
data is dependent on the quality of the input data.
2.4. Focus on hazardous waste
2.4.1. Hazardous waste generation – CDW, a major share in hazardous waste

amounts
According to a European Environment Agency (EEA) study on hazardous waste published in June 201516,
CDW holds a major share in generated hazardous waste amounts across several Member States. For
example in Germany, 32% of generated hazardous waste can be allocated to LoW chapter 17 ‘construction
and demolition waste’ in 2012. A major share of imported waste amounts to Germany that are classified as
hazardous according the LoW are also CDW.
More generally, hazardous CDW is an important stream of hazardous waste in EU-28 (17% on average in
2012, including contaminated soils and dredging spoils) and includes different categories:
 53% of mineral waste from construction and demolition (HAZ W121): concrete, bricks and gypsum
containing hazardous substances, Tarmac ® and asphalt road covering containing hazardous
substances, CDW containing mercury, insulation materials and other mixed CDW (e.g. plastic, wood,
glass) containing hazardous substances;
 38% of both contaminated soils (W126) and dragging spoils (W127) from NACE F (this waste
stream is excluded from the present study’s scope);
 8% of asbestos-containing waste (W12B): asbestos was commonly used as an insulating and
fireproofing agent in construction materials such as cement. Since asbestos has been identified as a
16
EEA (prepared by the ETC/SCP and ETC/WMGE), 2015, “Hazardous waste review in the EU-28, Iceland, Norway, Switzerland and
Turkey - Generation and treatment”
carcinogen product, asbestos-containing materials are no longer used. However, asbestos-
containing waste is a major issue for all MS as it is present in most of the renovation and demolition
projects.
 1% of wood waste (HAZ W075): wood sawdust, shavings, loss, particle panels and veneer
containing chemicals due to painting, lacquers and fungicides;
 The remaining hazardous CDW is relatively not significant in terms of quantity, while its
dangerousness for both human and the environment is of paramount importance:
o Glass waste (HAZ W071): powder or small particles of glass containing heavy metals,
such as special glazing;
o PCB-containing waste: fillers, synthetic soil covering, double glazing, disused transformers
and condensers containing PCBs are commonly found in renovation and demolition works.
PCBs are also identified as potentially carcinogen substances and thus require separate
collection and proper treatment.
o Other hazardous substances in finished works waste: lead-based paints were commonly
used before being forbidden in most countries in the late 1940’s and may thus be found in
renovation and demolition works. In general, CDW may contain paint and lacquer waste,
wood treatment substances, toxic solvents, adhesives, coatings, lamps, mercury containing
equipment. These various hazardous waste products all need specific management
practices (identification, separate demolition, separate collection, proper treatment).
The pattern for hazardous CDW generation is slightly different to the total waste generation with Germany
and the Netherlands generating a larger amount of hazardous waste relative to the construction
industry turnover (above 20 tonnes/million Euros). This could be due to the length of time and stringency of
waste management regulations that have been implemented in these two countries. For example, Germany
and the Czech Republic have guidance for identification and management of hazardous waste. However,
other countries with similar characteristics do not show such high levels of hazardous waste generation. A
more in depth evaluation of hazardous waste regulatory compliance requirements, over time and across the
EU would be necessary to determine the underlying reasons for these outliers.
On the other hand, Bulgaria, Greece, Latvia, Ireland and Romania show the lowest amounts of CDW
generated taking into account the turnover rate of the construction sector (ranging between 0.02 and
0.12 tonnes/million Euros). The countries that appear to produce the smallest amounts of hazardous CDW
relative to turnover tend to have lower data quality scores than those producing higher amounts. This might
suggest that the amount of hazardous waste is under-reported in these countries. Previous validation
sessions of Eurostat statistics already pointed out inconsistencies in hazardous waste reporting in the case
of Latvia and Romania17 18. For Bulgaria and Greece, the overall drop of total CDW in NACE F is due to the
economic slowdown19, but no specific explanations were provided for the decrease of hazardous CDW in
2012. Moreover, in the case of Greece, CDW may be underestimated due to some shortcomings in
environmental permits for treatment facilities used as administrative sources to estimate both produced and
treated waste amounts20.
For Greece, Latvia and Romania it is reported that data may not be properly reported or not reported at all.
In Latvia, illegal dumping is thought to be a problem due to a lack of resources so enforcement is not carried
out properly. Similarly, in Greece, the issue of illegal CDW disposal is not being tackled due to a lack of
enforcement/delays in applying the laws.
17
18
ICEDD asbl, Waste Statistics in Depth Validation - Reference Year 2012. Data Validation Description and Country Fact Sheets (For
EUROSTAT, October 2015), p. 109.
19
20
25
20
Tonnes/Million Euros
15
10
Average, 4.5
5
Figure 15: Hazardous CDW generated per €Million turnover, 2012

The breakdown of CDW generated into hazardous and non-hazardous has been calculated as shown in
Figure 16. For some countries, there is a major variation in the amount of hazardous CDW generated as
a proportion of the total. Sweden (13%), Denmark (8%) and the Netherlands (7%) generating a much
larger proportion of hazardous waste, whereas 11 countries reported generating less than 1%
hazardous CDW. This could be due to better governance in these countries, which means that hazardous
waste is identified and managed better. Sweden, Denmark and the Netherlands all have established policies
for reducing hazardous waste and dealing with legacy waste, whereas those MS producing less than 1%
hazardous CDW have limited policies in place (based on the maturity matrix assessment in 3.3 report). In
addition, the Member States producing lower levels of hazardous CDW appear to have limited legislation in
place or limited enforcement.
A number of MS (Hungary, UK, Ireland, Poland, Slovakia and Sweden) require pre-demolition audits or
inventories/surveys to identify hazardous waste present and in particular, asbestos. These requirements are
usually linked to the demolition permit/licence and the driver is health and safety. This type of legislation has
usually been in place for 5-10 years. However, the levels of hazardous CDW vary considerably between
these so it is not possible to draw any conclusions about the impact of mandatory pre-demolition audits on
the amount of hazardous CDW produced.
100 Average, 97.5

98
96
94
92
%
90
88
86
84
82
80
Latvia
Romania
Bulgaria
Malta
Lithuania
Hungary
Finland
Italy
Estonia
France
Slovenia
Slovakia
Poland
Belgium
Croatia
Netherlands
Sweden
Greece
Ireland
Cyprus
Germany
Austria
Czech Republic
Spain
Portugal
Luxembourg
Denmark
United Kingdom
% non-hazardous CDW % hazardous CDW Average % non-hazardous CDW
Figure 16: Breakdown of CDW generated, 2012

As shown in Figure 17, hazardous CDW generated by Member States is mainly composed of hazardous
mineral waste from construction and demolition (W121) or other mineral waste containing asbestos (W12B).
There is an apparent gradient of waste type compositions ranging from 100 % of hazardous mineral waste
from construction and demolition (W121) in Ireland and Romania to 100% of hazardous other mineral waste
containing asbestos (W12B) in Cyprus. No waste containing asbestos is being reported by some Member
States, which suggests that asbestos is not being collected separately from other mineral CDW. The
asbestos may be mixed with hazardous or non-hazardous mineral waste. For instance, in the case of
Ireland, asbestos waste is produced in the country, but does not appear in Eurostat statistics21.
Moreover, the diverse patterns of hazardous CDW composition across the EU Member States might also be
due to incorrect assignment of waste to the correct waste categories.
This figure should also be carefully read in light of Figure 15. For instance, the implausible low relative
amounts of hazardous CDW reported by some Member States (i.e. Romania, Latvia, Greece and Bulgaria)
due to inconsistent reporting might in fact not be representative of the “actual” amount of hazardous waste
generated in the country.
100%
90%
80%
70%
60%
50% W12B
40% W121
W077
30%
W075
20% W071
10%
0%
Romania
Finland
Slovakia
Latvia
Hungary
Estonia
Belgium
Ireland
Bulgaria
France
Germany
Netherlands
Sweden
Slovenia
Czech Republic
Italy
Croatia
Poland
Lithuania
Malta
Cyprus
Portugal
Spain
Austria
Greece
United Kingdom
Denmark
Luxembourg
Figure 17: Breakdown of hazardous waste generated in 2012
Note: W071 = glass waste; W075 = wood waste; W077 = waste containing PCBs; W12B = Other mineral waste
containing asbestos (excl. C&D waste, combustion waste, soils, dredging spoils, waste from waste treatment); W121 =
mineral waste from construction and demolition
21
Personal communication with Conor Walsh from SLR Consulting Ireland (January 2016)
2.4.2. Hazardous waste treatment – A concentration of treatment facilities in a
selection of Member States
The breakdown of hazardous and non-hazardous CDW treated by each MS is summarised in Figure 18
below. This is based on Eurostat data of waste treated in 2012.
100% Average, 0.98
95%
90%
85%
80%
75%
Non-hazardous waste Hazardous waste Average % non-hazardous
Figure 18: Breakdown of treated waste

This shows that Sweden, Denmark, the Netherlands and Germany treat a much larger proportion of
hazardous CDW than the average. This is in line with the previous analysis of hazardous CDW generated
as a proportion of all CDW generated with these four countries producing a larger proportion of hazardous
CDW.
In addition, Sweden, Denmark, the Netherlands and Germany all import hazardous CDW whereas Ireland,
Austria, Malta, Croatia and Greece all export hazardous CDW. Exports of hazardous CDW is a reality in a
series of Member States which are not equipped for dealing with the specific treatment of these waste types.
While these CDW have to be declared as being generated, they do not appear in the national statistics as far
as treatment is concerned (the MS importing these CDW accounts for these additional amounts of treated
waste in their own statistics). This phenomenon of hazardous CDW exports is often correlated with the size
of the country (e.g. in Malta, Cyprus and Luxemburg). Small countries are likely not to invest in appropriate
facilities for hazardous waste handling, probably more expensive than exporting this waste. Hence, in such
countries, due to the lack of appropriate facilities for hazardous waste handling, most of hazardous CDW has
to be exported for treatment 22,23.
22
‘Quality Report for 2012 Waste Data Reported by Malta’s National Statistics Office (NSO), Eurostat Metadata’.
23
‘Email Communication with Mrs Nadine Mercieca, Senior Environment Protection Officer, EU Affairs at Environment
Protection Directorate - MEPA, on Behalf of the Malta Environment and Planning Authority (MEPA) and Ministry for
Sustainable Development, the Environment and Climate Change (MSDEC) of Matla, April - May 2015 (task 1)’.
Figure 19 below shows the percentage of the different processing operations performed on hazardous
mineral CDW compared to the total amount treated (with still 7 countries not reporting data).
100%
90%
80%
70%
60%
Recycling
50%
Backfilling
40%
Energy recovery
30%
Incineration
20% Landfilling
10% Other disposal
0%
Finland
Bulgaria
Latvia
Slovakia
Belgium
Romania
Hungary
Estonia
Sweden
Cyprus
Ireland
Malta
Netherlands
France
Germany
Slovenia
Italy
Poland
Croatia
Austria
Czech Republic
Spain
Lithuania
Greece
Portugal
Luxembourg
Denmark
United Kingdom
Figure 19: Share of each treatment operation compared to the total amount of hazardous mineral CDW treated in
EU Member States for the year 2012
This figure shows EU MS achieving contrasting performances. Whereas the Netherlands, Denmark and
France recycled more than 90% of the treated waste, countries such as the United Kingdom, Estonia,
Lithuania, Croatia and Portugal incinerated or landfilled it.
In the Czech Republic, all hazardous CDW seems to be backfilled but this seems to be a reporting problem
due to the absence of a specific code for backfilling in the country and at EU level. National authorities
further confirmed that backfilling of hazardous waste is not actually taking place in that country. Unfortunately
there is no information available on the actual treatment operation for hazardous CDW in the Czech
Republic.
The percentage of treated waste that is recovered has been analysed based on Eurostat data for waste
management route RCV_0, Recovery other than energy recovery - Except backfilling. This has been
calculated for 2012 for total CDW treated, hazardous CDW treated and non-hazardous CDW treated as
shown in Figure 20.
100
90
80
70
60
%
50
40 Average, 33.6
30
20
10
0
Figure 20: % Hazardous CDW recovered

As seen in Figure 20, the Netherlands, Denmark and France recover (RCV_O, Recovery other than energy
recovery- Except backfilling) a high proportion of hazardous CDW but almost half the MS do not recover
any hazardous CDW waste. In these cases, hazardous waste is either landfilled or incinerated (INC,
without energy recovery and RCV_E, incineration/energy recovery).
2.5. Focus on backfilling
The definition of the CDW recovery target in the Waste Framework Directive (WFD) enables MS to include
the volumes used for backfilling into the calculation of their national CDW recovery target. But the WFD also
requires that MS “shall take measures to promote high quality recycling”, which is contradictory.
Also, as the WFD itself does not provide a definition for backfilling, there is a relative confusion among
Member States (MS) concerning the term backfilling and its application as a recovery or a disposal
operation. This results in a considerable variation in the reporting systems applied by MS to demonstrate
their performance against the Article 11 (2) 70% target for construction and demolition waste.
2.5.1. Definition of “backfilling” – A Eurostat guidance that tends to clarify the

WFD definition
24i
‘Backfilling’ is not a term which has been defined in the Waste Framework Directive (WFD) however it is
included in the target for re-use and recycling of CDW within Article 11/2b:
‘By 2020, the preparing for re-use, recycling and other material recovery, including backfilling operations
using waste to substitute other materials, of non-hazardous construction and demolition waste excluding
naturally occurring material defined in category 17 05 04 in the list of waste shall be increased to a minimum
of 70 % by weight.’
To provide rules and calculation methods for demonstrating compliance to the 70% CDW target, the
Commission Decision 2011/753/EU25 was published and a definition was given in Article 1 (6):
‘Backfilling’ means a recovery operation where suitable waste is used for reclamation purposes in excavated
areas or for engineering purposes in landscaping and where the waste is a substitute for non-waste
materials.’
24
http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32008L0098&from=EN
25
http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32011D0753&from=EN
According to this definition, backfilling meets the definition for “recovery” under the WFD (since it “serves a
useful purpose by replacing other materials which would otherwise have been used to fulfil a particular
function”), but fails to comply with the specific requirements for recycling (or for preparation for re-use).
Hence, backfilling can be considered as low quality recovery, as energy recovery and the reprocessing
into materials that are to be used as fuels.
There is no specification of the type of waste other than it has to be “suitable” but in the context of the
70% WFD CDW recovery target, this must exclude naturally occurring material defined in waste category 17
05 04, i.e. soils & stones. Also, it can be deduced with reference to the Landfill Directive that only inert
waste with minimal potential for environmental risk would be “suitable” for such lightly regulated activities
and be able to replace non-waste materials. This inert waste will only include concrete, bricks, tiles and
ceramics.
However, this definition still failed to substantiate the claim of backfilling as a recovery operation, since MS
could still report CDW stored in spent quarries as reclamation activity regardless if that purpose was
intended or not. The vague interpretation of backfilling as a recovery operation could lead to increased
recovery rates, while in reality CDW is treated similarly to landfilling but with the only difference of filling in
void underground spaces instead of taking space on the surface areas of designated landfills.
To provide assistance on how ‘backfilling’ should be reported, Eurostat produced a document: ‘Guidance on
the interpretation of the term backfilling’26.
The guidance specifies the following aspects:
 Any backfilling operation has to comply with the recovery definition by replacing other materials or
being prepared to fulfil a particular function.
 Associated with the term backfilling is the notion of a permanent placement of the material on/in
particular sites, it is not intended to be returned to the economic material cycle.
 The condition of substituting other (non-waste) materials suggests that the reclamation or
landscaping measures will be undertaken anyway, whether a suitable waste for this purpose is
available or not.
2.5.2. Potential modification of the definition of “backfilling” introduced by the

Circular Economy Package – A risk of considering the production of
recycled aggregates as backfilling
On the 2nd December 2015, the European Commission announced the adoption of a Circular Economy
Package, which includes revised legislative proposals on waste. This includes proposed changes to the
WFD Directive 2008/98/EC with regard to the definition of ‘backfilling’ and the wording of Article 11 2/b.
Article 11 2/b is modified as follows: ‘By 2020, the preparing for re-use, recycling and backfilling of non-
hazardous construction and demolition waste excluding naturally occurring material defined in category 17
05 04 in the list of waste shall be increased to a minimum of 70 % by weight’.
Key changes are that the words ‘material recovery’ and ‘using waste to substitute other materials’ have been
removed.
In addition, a definition for backfilling has been introduced, which is to replace the definition within
the Commission Decision 2011/753/EU:
"backfilling" means any recovery operation where suitable waste is used for reclamation purposes in
excavated areas or for engineering purposes in landscaping or construction instead of other non-waste
materials which would otherwise have been used for that purpose.
The new definition has added engineering purposes in construction. Yet, as stated in the WFD
definition of recycling (article 3/17), recycling “does not include […] the reprocessing into materials that
are to be used […] for backfilling operations”
Consequently, if this proposed expansion of activities considered to be backfilling is applied, it is likely to
result in all suitable waste reprocessed into aggregates to standards and specifications for construction
26
Eurostat Guidance on the interpretation of the term backfilling
engineering being re-classified as backfilling rather than recycling, unless they have ceased to be waste
by meeting the WFD end of waste criteria.
2.5.3. Inclusion of backfilling in the EU 2020 target – A disputable statement

toward high quality recycling
Having excluded soil, stones and dredging soil (waste code 17 05 04), the other CDW waste codes for waste
which may be inert and suitable for backfilling activities (‘reclamation purposes in excavated areas or for
engineering purposes in landscaping’) are: 17 01 01 Concrete, 17 01 02 Bricks, 17 01 03 Tiles & ceramics
and 17 01 07 Mixtures of concrete, brick, tiles & ceramics.
Table 5: CDW suitable for backfilling
CDW suitable for backfilling Included in Recycling potential at higher Recycling

scope of quality/value than backfilling within scope of
WFD CDW EN product
70% target Quality
Standards
Aggregates Glass
17 01 01 Concrete Yes 100% n/a Yes
17 01 02 Bricks Yes 100% n/a Yes
17 01 03 Tiles and ceramics Yes 100% n/a Yes
17 01 07 Mixtures of concrete, Yes 100% n/a Yes

bricks and ceramics
17 02 02 Glass Yes 100% 100% Yes
17 05 04 Soils and stones No Minimal n/a n/a
The WFD Article 11 requires that ‘Member states shall take measures to promote high quality recycling and,
to this end, shall set up separate collections of waste where technically, environmentally and economically
practicable and appropriate to meet the necessary quality standards for the relevant recycling sectors.’
High quality recycling of waste coded 17 01 01/02/03/07 and suitable waste coded 19 12 09, is in the
production of aggregates to meet Construction Products Regulations harmonised European aggregates
product standards, which are mandatory in all EU MS.
Hence, the inclusion of ‘backfilling’ of such ‘suitable’ waste to achieve the 70% target for re-use,
recycling and recovery within Article 11/2b is contrary to the primary objective of high quality
recycling to quality standards.
Another point is that Eurostat guidance adds that ‘the reclamation or landscaping measures will be
undertaken anyway, whether a suitable waste for this purpose is available or not.’
The reporting by MS of mines and quarries as recovery through backfilling with suitable waste implies that, in
the absence of that waste, such restoration would have been accomplished by purchasing material from
other quarries or mines is highly unlikely.
Backfilling activities and their level of likely compliance within the scope of the WFD are shown on Table 6
below. Within the current practices considered as backfilling, only reclamation of excavated areas in
construction could be considered as compliant with the WFD backfilling criteria, as it substitutes non-
waste materials and would be undertaken anyway if waste was not available (for more details on this
recommendation, see paragraph 6.5. “Remove the backfilling barrier”)
Table 6: Backfilling activities and their likelihood of compliance with the WFD criteria, and their environmental
risk
Activities within the scope of WFD backfilling Likelihood of compliance with WFD Suitability of Environ
(excluding Dec.’15 Circular Economy Package backfilling criteria* activity for mental
proposals) recovery of Risk*
Substitution of Activity Not
waste code
non-waste would intended
17 05 04
materials take to be
Soils and
place if returned
Stones
waste to the
was not economic (i.e. not
availabl material included in
e cycle WFD 70%
target)**
Reclamation of excavated areas (in Medium High High High Low

construction) (see Figure 21)
Construction earthworks, i.e. engineering works

involving the movement of soils and stone on a
construction site, may require some of the soils and
stone to be dug out and removed from the site
because they are they are unsuitable for
construction applications on that site. The hole or
holes created are referred to as voids. These voids,
or sections of the voids, may require raising to
construction design levels with infill materials that
have engineering properties meeting the technical
material specifications for the construction works.
Reclamation of excavated areas (mines and Low Low High High Low
quarries) (see Figure 22 and Figure 23)
The commercial extraction of minerals from mines

and quarries, i.e. mining and quarrying, also creates
voids. The infilling of these voids with
environmentally suitable materials may enable the
restoration of the land for agriculture or
development.
Landscape engineering (see Figure 24) Low Low High High Low
Construction works may include the shaping of the

land around a building project to improve the visual
appearance of an area and/or to provide some
degree of screening to provide privacy or to reduce
noise. These works are designed and engineered to
fulfil a specific function and carried out with
materials meeting a construction material
specification. Landscape engineering may also be
undertaken as part of the final restoration of
landfills, see “Covering landfills” section below.
Covering landfills (see Figure 25) Low High High High Low
This activity takes place during the final restoration

works on a completed landfill e.g. when a landfill
has been sealed by capping and requires soils to
return the land to farming. EC guidance advises that
landfill restoration may be defined as ‘backfilling’ if
the waste is used instead of other virgin materials,
suitable for the application (complying with the
necessary properties for the particular
performance), and applied in a process of
landscaping engineering.
* An entry of ‘High’ against an activity indicates that there is a reasonable prospect of compliance with that element of the
WFD requirements. An entry of ‘Medium’ indicates that compliance with the WFD target is possible and this is explained
in more detail in the Note to Table 5. An entry of ‘Low’ indicates that compliance with that element of the WFD
requirements is highly unlikely.
** This is included to emphasise the point that suitable materials with waste code 17 05 04 are highly appropriate for the
listed activities and are a more sustainable option for the use of resources.
***Environmental Risk relates to the likely impact of the use of inert CDW on groundwater relative to each activity, this
risk will increase where groundwater protection is a critical consideration; an entry of ‘Low’ indicates that there is a small
risk.
Note: There is a medium chance of replacing non-waste materials and that is in excavated areas in construction. A
construction project may have a clear need for a resource to fill a void, if hard inert CDW is not available, they may first
look at infill soils (17 05 04) and lastly at crushed rock, i.e. virgin material. Other activities are likely to have a low
possibility of substitution with non-waste materials. This is due to the fact that quarries sell their materials and are
therefore not likely to be backfilled; mines are only backfilled with virgin materials when there is a planning/legal
obligation to infill and groundwater risks requiring the use of specific aggregates, however this is rare; landscape
engineering usually uses on-site excavation waste (17 05 04). The same excavation waste would be the first choice for
screening banks and virgin materials will be the last resort if waste was not available; and the final covering of completed
landfills is sub-soil or clay. Virgin aggregates are unsuitable and extremely unlikely to be considered as an option.
Figure 21 : Reclamation of excavated areas (in construction) - earthworks27
27
Sourced from: http://grounddevelopments.co.uk/ground-improvement/soil-stabilisation/
Figure 22: Reclamation of excavated areas: restoration of a mine (before and after)28
Figure 23: Reclamation of excavated areas:filling in a quarry void29
Figure 24: Landscape engineering: an example of a noise bund/barrier30
28
From: https://www.intechopen.com/books/advances-in-landscape-architecture/reclamation-of-degraded-landscapes-due-to-opencast-
mining
29
From : http://www.chelvertondevelopments.co.uk/projects/chipping-sodbury
30
Sourced from: https://www.newcivilengineer.com/latest/gatwicks-premium-bund/8624222.article
Figure 25: Covering landfills: capping of a landfill31
Table 7 provides examples of recycling applications for processed inert mineral CDW and applications for
unprocessed inert waste. The applications for the uprocesssed inert mineral CDW are demonstrated to be
either backfilling, if waste is replacing a non-waste, or landfill if waste is not replacing a non-waste. These
acitvities are within the scope of the WFD backfilling, as per Table 6.
Table 7: Examples of applications for processed and unprocessed inert mineral CDW
Applications for processed inert mineral CDW Recycling Backfilling Landfilling
Aggregate meeting specification for unbound road layers (sub- 
base)
Aggregate meeting drainage aggregate specification 
Fine aggregate to tennis court sand specification 
Aggregates meeting specification for unbound road layers for use 
in agricultural paths
Aggregates to engineering specifications for trench fill 
Aggregates for engineering fill to earthworks specifications e.g. in 
noise barriers etc.
Aggregates for engineering fill to earthworks specifications for 
dams
Applications for unprocessed inert mineral CDW Recycling Backfilling Landfilling
Reclamation of excavated areas (in construction) – the raising of holes(voids) to construction design levels
Waste replacing non-waste resources as bulk filling material for 
dams
Reclamation of excavated areas (mines and quarries) - the filling of the holes (voids) for restoration purposes such as
agriculture or development
Waste replacing non-waste resources in restoration of quarries 

Waste not replacing non-waste resources in restoration of
quarries

Waste replacing non-waste resources in restoration of mines
31
http://www.deme-group.com/references/capping-category-iii-landfill

Waste not replacing non-waste resources in restoration of mines
Landscape engineering – can include the shaping of the land to improve the visual appearance of an area and/or to
provide some degree of screening to provide privacy or to reduce noise or development of pathways
Waste replacing non-waste resources as filling material in 

landscaping e.g. in noise barriers
Waste replacing non-waste resources as unbound layers for 
agricultural paths
Covering landfills - the final restoration works on a completed landfill
Waste replacing non-waste resources in restoration of landfills 
The following checklist can be used to establish if an activity can be considered as backfilling.
Table 8: Checklist to establish if an activity can be considered as backfilling
Criteria for assessing validity of an activity as backfilling

1. Would the construction, reclamation or landscaping activity
be undertaken whether a waste suitable for this purpose is
available or not?
2. Does the waste substitute a non-waste material?
3. Are the wastes suitable inert construction wastes within the
scope of WFD CDW 70% target and exclude waste code In all cases where one or more
17 05 04 soil and stones? of the responses are NO, the
4. Is the use of the waste permanent with no intention of activity cannot be classified as
returning the material to the economic cycle? Backfilling in the context of the
5. If the activity is the reprocessing of waste into materials that WFD CDW 70% target.
are to be used for backfilling operations do the proposed
backfills meet all criteria 1 to 4 above?
The inclusion of ‘backfilling’ as a poorly defined option for ‘recovery’ within Article 11 2/b results in
inconsistency in CDW data reported by MS. Activities classified as ‘backfilling’ vary depending on
established practices in different MS and matters are more confused by widespread land recovery through
restoration with inert soils (waste code 17 05 04), which involve a waste and a recovery process excluded
from the 70% target in Article 11 2/b.
The inclusion of the term ‘backfilling’ in the present wording of Article 11 2/b has caused, and
continues to cause misunderstanding, creating a disincentive to achieving the resource efficient
objective of high quality recycling to quality standards.
This point is supported by the 2014 report completed for the Nordic Council of Ministers and titled ‘ENCORT-
CDW: Evaluation of the European recovery target for construction and demolition waste’32, in which one
main conclusion was: “The EU recovery target does not ensure a sustainable waste recovery in its present
form as it does not favour the most sustainable recovery operations. Above all, it does not distinguish
between backfilling and other more resource efficient recovery operations. Since backfilling is a recovery
option that generally results in both low benefits and future environmental risks, this increases the risk for
“downcycling”, which means that the waste is not recovered in the most optimal way”.
Excluding backfilling from the WFD recovery is an option recommended by the Swedish Geotechnical
Institute as presented at the workshop33. Findings from the workshop, indicated that two-thirds of attendees
were unsure as to whether backfilling should be excluded from the WFD target. This suggests that there is a
lack of awareness and understanding of the issues related to backfilling. These issues should be
communicated more widely across MS. It is also vital to develop a better understanding of the impact of
removing backfilling from the target for MS where backfilling rates are high and included in their recovery
target.
32
http://norden.diva-portal.org/smash/record.jsf?pid=diva2%3A724760&dswid=8234
33
Presentations available at: http://ec.europa.eu/environment/waste/studies/mixed_waste.htm
2.5.4. Interpretation and reporting of backfilling by MS – Various practices
among Member States
Despite the guidance document on ‘backfilling’ provided by Eurostat there is significant variation between the
ways in which individual MS define and report ‘Backfilling’ as part of their internal regulations designed to
report on the WFD Article 11 target for re-use, recycling and recovery of CDW.
The official percentage of CDW that is backfilled on average is quite small (<6%) but the current backfilling
figures seem to be underestimated in Eurostat statistics and the share reported as being backfilled
varies consistently from one Member State to another. More information on the statistical treatment of
backfilling at EU level is available in section 3.3 of this report.
Task 3 further analysed the backfilling approach taken by Germany, Austria, and that of Malta and Poland,
which show a clear difference, even if cross-analysis of these four examples was difficult due to
inconsistencies in reporting and the varying degrees of confidence that can be attributed to the accuracy of
some data.
Germany and Austria have a high rate of recycling and an established market for recycled
aggregates. They also discourage backfilling of resources suitable for processing into aggregates whilst
promoting legislation for the beneficial use of excavation waste/soils in the restoration and landscaping of
land. In Germany, this is achieved through a high CDW landfilling cost and tight regulation for the use of
waste in landscaping and restoration in most German states. This is in line with the requirements arising
from environmental provisions associated to waste legislation and laws related to soil (Bundes-
Bodenschutzgesetz (BBodSchG) and the Bundes-Bodenschutzverordnung (BBodSchV)) and groundwater
(Wasserhaushaltsgesetz (WHG)). In Austria, backfilling is strictly controlled and permitted as a form of
recovery only if the following criteria are fulfilled:
 Substitution of other material for a concrete purpose (structural engineering),
 Quality comparable to that of the substituted product by a quality assurance system,
 Limited use to an extent absolutely necessary for reaching the goal of backfilling.
Malta and Poland are dependent on activities classified as backfilling to reach the WFD 70% recovery
target for CDW. Malta permitted a number of quarries for backfilling operations, whereby clean inert waste is
recycled and/or backfilled. In 2009 all of these licences were revoked and quarry owners which were still
interested in pursuing this activity submitted an application for an environmental permit under 2011
legislation for backfilling or recycling inert waste This is to prevent CDW taking up landfill space and to use it
to restore exhausted and operational quarries; however the CDW is not a substitute for non-waste materials.
Until recently, the backfilled CDW volumes were reported as landfilled and are still reported as such in
Eurostat data. However, under the light of the possibility of using backfilling as recovery in the calculation of
the WFD target, Malta is considering reporting the entire volume of CDW backfilled in spent quarries as
recovered and thus would reach an extremely high recovery rate.
For Poland, the reporting of performance against the WFD 70% recovery target for CDW includes backfilling.
This activity has, within its scope, stowage of suitable CDW in mines and quarries, land rehabilitation and
landscaping. Poland has introduced new legislation to include more activities in the scope of backfilling,
which could be viewed as a backward step by discouraging the use of suitable CDW into aggregates. These
activities include:
 including filling areas negatively transformed, such as landslips, opencast workings, depleted
workings
 hardening land surface
 using in underground mining techniques
 performing minor repairs and maintenance
 construction, reconstruction or renovation of tracks and track bed, embankments, railway
embankments, road and highway foundations, impermeable linings, cores of hydraulic structures,
and other buildings and structures, including foundations
 construction, development and maintenance of other hydraulic structures, such as artificial islands,
structures and installations, submarine cables and pipelines, piers, embankments, platforms, silting
fields, and other port infrastructure items, flood control structures, shore protection.
Finally, in MS which still incorrectly include soils in CDW generation and treatment data for the
calculation of the WFD recovery target (e.g. Hungary, Cyprus), backfilling might distort the recovery rates
and influence positively or negatively the level of these recovery rates, leading to a false rate and
jeopardising the potential achievement of the WFD target.
3. Plausibility of official CDW
statistics
As part of task 4, the overall data quality of EU MS was assessed through different methods and by using
different available information sources. This section draws the overall conclusions that arose through
analyses of data quality. This part also highlights key elements to improve data quality in the future.
3.1. CDW data quality in EU MS – Further improvements needed in most Member

States
Three categories of quality for the CDW data in the EU have been created, i.e. poor, modest and good
quality levels. The method used for classifying MS with regards the quality of their CDW data is the Natural
Threshold (Jenks) Method, using the ARCGIS software34. Category limits are located at the highest
differences between values. This method, based on natural gathering existing in the data, therefore allows
similar values to be grouped and differences between categories to be optimised. On the whole, this study
highlights the overall modest quality of reported CDW data in the EU. In average, the CDW data is given a
quality score of 2.3/5 with a range from 1.5 to 4.3. For most of MS, further improvements are therefore
needed in terms of collection and reporting of CDW data to the EU.
Table 9: Levels of overall CDW data quality in 2012 (MS are classified by alphabetical order in each category)
Good Modest Poor
Austria Belgium Bulgaria
Czech Republic Estonia Sweden
Denmark France Cyprus
Germany Hungary Finland
The Netherlands Italy Greece
Poland Lithuania Ireland
Portugal Luxembourg Latvia
Slovakia Spain Malta
Slovenia United Kingdom Romania
Croatia
Most MS presenting a similar quality data are geographically clustered. Member States characterised by
good quality CDW data are nearly all located in central Europe. These form an important area from The
Netherlands to Poland in the W-E direction, and from Danemark to Slovenia in the N-S direction. Portugal
also presents a good level of CDW data quality while it is not geographically close to other MS in the same
category. At the opposite, one third of EU MS display poor quality CDW data. Among them, 4 are located in
Northern Europe (i.e. Sweden, Finland, Latvia and Ireland) and 6 in Eastern Europe (i.e. Romania, Bulagria,
Greece, Cyprus, Malta). In addition, France and Lithuania also suffer of a poor quality in terms of anomalies
in their data sets while these have an overall modest data quality because of their more robust data
collection methodologies compared to other countries.
34
More details on the methodology of classification can be found in Task 4 report, Chapter 3.1.
Figure 26: Spatial distribution of the overall data quality in the EU in 2012
Note: Good in green, modest in yellow, poor in red

As far as the poor level of CDW data is concerned, MS display a high number of abnormal values, as
detected by advanced statistical tests, for a series of waste types. In addition, these statistical issues are
often related to shortcomings in their data collection methodology. The good quality of the CDW data in
Central Europe (i.e. Austria, Czech Republic, Denmark, Germany, The Netherlands, Poland, Portugal,
Slovakia and Slovenia) is characterised by the small number or the absence of anomalies detected by
statistical tests and also reflect on their good practices in terms of data collection methodologies.
Table 10 below presents a summary of all issues impacting the CDW data quality (i.e. concerning the data
collection methodology, some inconsistencies with both national and international data and series of
unexplained statistical anomalies as outliers, suspicious null values and abnormal temporal evolution).
Table 10: Summary of all types of issues impacting the CDW data quality and associated examples
#
Type of problems Examples Possible explanation
MS
In Greece, the number of economic sectors (NACE codes) in Eurostat statistics in which
27
Waste amounts of CDW are reported is too low. W121 are only reported in NACE code F
(vs.
production (construction and demolition sector). This leads to an inaccurate estimation of CDW
28)
waste in general, as other sectors are also supposed to generate CDW.
In Latvia and Finland, there is neither a legislative definition for backfilling, nor any
25
Data collection Waste official classification code for backfilling, nor available data for backfilling in Eurostat
(vs.
methodology treatment statistics. Hence, they seem to be reporting backfilling data as recovery as it has no way
28)
of estimating the share of backfilling performed in the country.
Cyprus, Greece, Ireland, Italy, CDW are landfilled in landfills other than
Waste 15
Latvia, Malta, The Netherlands and inert landfills (e.g. landfills for non hazardous
treatment (vs.
Romania do not report any estimation waste);Unauthorised landfill sites are still
capacities 28)
for their remaining capacities. operating.
Hungary: higher amounts of mineral
waste from construction and The national detailed data are not yet
4
Waste demolition (W121) in Eurostat statistics extrapolated to the whole country for WStatR
(vs.
Inconsistencies production across all NACE activities (3.3 Mt) reporting and are therefore likely
9)
with detailed compared to national detailed data underestimated.
national data (1.3 Mt)
In Denmark, Eurostat statistics are
7
Waste higher for recycling and lower for The exact reasons for these discrepancies are
(vs.
treatment landfilling than the national detailed unknown.
8)
data.
Austria produced 4.000.000 t of
Inconsistencies with 28 35 The recycled CDW reported in Eurostat data
recycled aggregates (UEPG ), while
international data (vs. includes waste other than recycled
national statistics report 5.786.101 t of
(see sheets by country) 28) aggregates.
recycled mineral CDW.
The amount of W121 reported by Malta uses indirect estimates of generated

Malta (664 kt/€ or 500 kt) is far above waste, based on amounts of treated CDW
8
Abnormal high the median amount for this type of reported by treatment facilities. In this specific
(vs.
values CDW across all other economic case, this induces a double counting,
28)
sectors corrected by the turnover (107 explaining the overestimation of treated CDW,
Unexplained
kt/€). and indirectly of generated CDW.
outliers
Both Bulgaria and Romania reported These MS are likely not collecting asbestos
7
Abnormal low only 1 tonne of hazardous mineral separately from other mineral CDW. In this
(vs.
values CDW containing asbestos (W12B). case, asbestos may be mixed with hazardous
28)
mineral waste.
Reported values of metallic waste MS often have inadequate information on

(ferrous, nonferrous and mixed - 06.1, metallic scrap due to no clear classification of
Unexplained 16 6.2 and 06.3 respectively) in six MS these material waste types. The classification
Waste
suspicious null (vs. (e.g. Latvia) are null, which is likely not into this category is very unclear for some
production
values 28) accurate according to common companies, because EWC contains many
construction and demolition practices codes. This explanation was for example
in most EU MS. raised by Latvia.
This is due to the methodological

14 Latvia shows a high decrease in weaknesses of the way CDW is estimated in
Abnormal temporal evolution (vs. generated non-hazardous waste Latvia, as there are some issues in
28)
from the construction sector (21 494 determining the source of waste.
35
UEPG, Annual Review 2013-2014 (Brussels: European Aggregates Association, 2013), p. 40 (p. 14)
<http://www.uepg.eu/uploads/Modules/Publications/uepg-ar2013-2014_v28.pdf>.
tonnes in 2010 to 7 432 t in 2012).
3.2. Good methodological practices – Recommendations to enhance data quality

and harmonise MS methodologies
Eurostat data are reported to Eurostat pursuant Regulation (EC) No 2150/2002 (referred hereafter as
WStatR). Several methods for data collection are accepted in order to comply with this reporting obligation.
This means Member States are allowed to use their existing administrative data sources as a basis for
preparing the data for WStatR reporting. Member States might also carry out a survey that might be
specifically designed for WStatR reporting. Moreover, several methods/models/surveys may be used to
complement the different data sources in order to provide a full picture of waste data generation and
treatment in the country36.
This variety of methodologies allows MS to reduce the burden on companies and on local administrations.
However this also means that many different methodologies lay behind the data reported to Eurostat,
even though the same classifications are used (for waste types, waste operations and economic
activities). Even though Eurostat and national statistical offices are constantly working together to improve
the data comparability across countries, some data is still difficult to compare due to the lack of
harmonisation in data collection methodologies. A strong improvement has however already been
observed since the first data collection year in 2004 on the matter.
As far as CDW data collection methodologies are concerned, we recommend the government and
statistical offices of Member States follow these guidelines to ensure the quality of CDW data. These are
based on observed good practices in most Member States characterised by good quality CDW data:
For Member States using surveys to collect data on CDW:
 The survey should be updated on a yearly basis; temporal extrapolations or interpolations based on a
survey carried out every two years are not recommended;
 The survey should cover a representative sample of industries (in terms of waste amounts or of
socio-economic indicators), following certain thresholds (e.g. 70%) based either:
o on the number of employees (e.g. as in Portugal),
o and/or on the generated amount of CDW (e.g. as in Slovenia),
This method allows the survey of the most important waste producers in order to reach a quantitative
representativity. However, some smaller producers have to be included for a matter of qualitative
representativity.
 An extrapolation of CDW data is often necessary when collected information do not entirely cover the
actual waste production and treatment deposits:
o First, the non-replying waste producers have to be estimated using data reported by similar units;
o Second, once the survey sample has been filled in, the issue is to calculate the percentage of
produced waste amounts for which data have been collected based on the survey, and hence
estimate the remaining part, i.e. the non-surveyed producers;
 For these extrapolation tasks, two statistical methods provide satisfying results:
o easily available socio-economic proxies (e.g. turnover and employment) are recommended.
The idea is to establish the correlation between a socio-economic proxy and the amount of
produced waste for the surveyed companies. On this basis, knowing the value of the proxy for the
other producers, the estimation of waste amounts can be easily obtained.
o Otherwise, another method consists in choosing the reporting unit within the same sector that
is most similar to the non-reporting unit. A possible method used to choose which unit is more
similar to the one missing is the nearest neighbour unit method37 (e.g. in Portugal). The
implementation of such a method must be achieved by advanced statistics experts.
36
Eurostat, p. 142.
37
The nearest neighbour method is a well-known optimisation algorithm used for data extrapolation, which does not need to build any
regression model (the model is the survey sample). This algorithm only needs both a distance function and a function of category
chosen depending on the nearest neighbours’ category. In this case, the distance is the difference between two values in the case of a
simple linear algorithm, or the Euclidian distance in the case of a multispace search (e.g. if firms are compared for each type of waste).
For Member states using administrative sources to collect data on CDW:
The key points are to avoid both the under coverage (and the subsequent underestimation of CDW
amounts) and the double counting (and subsequent overestimation of CDW amounts). This last issue is of
paramount importance when CDW generation data are estimated based on treatment data (secondary
information). Therefore, two efficient methods are recommended:
 The first recommendation is to adopt an input oriented approach for CDW generation data (e.g. as in
Germany), which means that treatment plants report directly to the NSO the amounts of waste received
for treatment (rather than the amounts of CDW leaving the plants). In order to improve CDW data
quality and to ensure a methodological consistency inside and among countries, we strongly
recommend that European Commission and Member States governments adapt the waste regulations
in this way (is case of Member States use administrative sources to collect data on CDW);
 Also, some MS (e.g. The Netherlands) have established systems (i.e. consignment registers) to ensure
the traceability of CDW: this is the ideal path to provide reliable statistics and to avoid double counting.
A is a registry used as a source to compile specific statistics on waste. The principle is that companies
that have a waste-permit are statutorily required to register each of their waste as far as they are
transported. When a waste transport has actually taken place, the shipped weight is linked to the “waste
stream code” and stored in the register. Hence, this easily allows quantifying each waste stream leaving
or entering any company. While the implementation of such a tracing system would entail important
costs and is probably not realistic in the short term in some Member States, we recommend the
European Commission communicates on this method and promotes its use on a voluntary basis;
In addition, we recommend the European Commission encourages all Member States to adopt the following
guidelines in order to improve consistency and comparability among Member states:
 Having a common definition of CDW : i.e. excluding dredging spoils (EWC code W127) and of soils
(EWC code W126) from the definition of CDW (these waste types are not supposed to be declared as
CDW according to the definition of CDW used by the EC, as explained in the section 2.1.1) ; some MS
(e.g. Finland) include soils in W121, leading to an overestimation of CDW amounts (see the section
5.1.2);
 Separately reporting backfilling data, even though a clear definition does not always exist in all MS;
 To ensure a cross-check of the CDW data by dividing the process of CDW data between different
national organisations closely cooperating. These kinds of collaboration also showed in some Member
States that each actor thoroughly achieve its task;
 To ensure a statistical control (quality checks) and correction of the data: external controlling
organisations (e.g. in Germany) or experts from NSO (e.g. in Czech Republic and Denmark) perform
manual checks (first undertaken by experts in the field and then by contacting respondents to clarify any
technical issue) and/or automatic checks;
 To include the imported CDW and to exclude exported CDW in the treatment table.
Therefore, some legislative tools should be used. The assessment of these practices should not entail
significant costs, as the aim for the European Commission is mainly about clarifying the way to proceed and
the aim for Member States is to adopt coherent procedures regarding member states characterised by high
quality CDW data.
3.3. Statistical treatment of specific materials/practices – Observed

discrepancies among Member States
3.3.1. Naturally occurring material defined in category 17 05 04 in the list of waste

(Soil)
One of the most important issues for CDW data quality is the misclassification of soil waste. Soils are
wrongly included in national estimated amounts of CDW in some MS (e.g. Lithuania and Finland). MS should
not consider all excavated contaminated soils (normally W12.6) in mineral CDW (W121). Among other
things, this impacts the calculation of the recovery rate related to the WFD target (risk of overestimation).
Also, this leads to an important overestimation of non-hazardous mineral waste from construction and
demolition (W121). Given that NHAZ W121 constitutes between 94% and 97% of the total amount of NHAZ
generated waste (depending on the Member State), the overestimation of this waste has a tremendous
importance on the total values reported.
3.3.2. Mineral waste from construction and demolition (W121)
In order to assess to which extent we may rely on the official CDW definition, national detailed data were
compared to the Eurostat statistics. It is not possible to draw general conclusions from the analysis
performed with the additional detailed national data provided, because only few countries provided these
data (9/28). However, when analysed with caution, it gives an indication on the fact that the more a country
reports mineral waste from construction and demolition (W121) in several NACEs and the more the weight of
these mineral waste in other NACES is important, the less we can rely on Eurostat statistics, in order to have
a correct appraisal of CDW data for other waste streams than W121. Indeed, we could assume that if
mineral waste from construction and demolition are reported in several NACEs, we could expect that other
waste streams originating from construction and demolition activities, for which we cannot track the waste
generating activity due to the EWC_Stat codes, might also be reported in different NACE activities (e.g.
wood waste, metallic waste, etc.). In the case of this study, we could only allocate the amounts reported in
the construction sector (NACE F) to construction and demolition activities for these waste streams and
probably underestimated the real amounts produced by this activity. The level of detail and the lack of
information on the generating activity in the current breakdown of Eurostat statistics do therefore
not allow having a correct appraisal of generated CDW amounts other than mineral waste from
construction and demolition (W121), in particular for those MS, which report important amounts of
W121 in other NACE sectors than NACE F. However, the disaggregation in 2010 of EWC_Stat code W12
into W12B and W121, already allowed to have a better insight on mineral waste from construction and
demolition (see Appendix A – Table 44 for more details on this breakdown).
3.3.3. Backfilling
Member States may include backfilling as a recovery operation when calculating the CDW recovery rate
pursuant the WFD38. Countries are also asked to report data on backfilling pursuant to Regulation No
2150/200239.
Figure 27 illustrates the amount of CDW backfilled in MS in 2012. It shows that the percentage of CDW that
is backfilled on average is quite small (<6%).
35
30
25
20
%
15
10 Average, 6.4
38EC, Directive 2008/98/EC of the European Parliament and of the Council of 19 November 2008 on Waste and Repealing Certain
Directives.
39
C, Regulation (EC) No 2150/2002 of the European Parliament and of the Council of 25 November 2002 on Waste Statistics.
Figure 27: The amount of CDW backfilled (from Eurostat) – ref. Report 3.1
Only 13 countries report data on backfilling in Eurostat statistics. Among the 15 countries that reported zero
amounts of CDW backfilled, 13 actually have backfilling operations. For these countries, it is an important
question whether the respective amounts are included in the recycled amounts (e.g. because they cannot be
reported separately) or whether the amounts are not covered at all.
According to the screening of all MS concerning backfilling information, it clearly appears that most of the
countries that reported zero backfilling do report actually backfilled CDW amounts in the recycled amounts
(RCV_O) and/or in the landfilled amounts (DSP_L). For instance, Malta reports an important share of CDW
as being landfilled, whereas the main part of it is reported as backfilled (in spent quarries) in national data.
Poland is an example of a Member State reporting high amounts of CDW being backfilled in Eurostat data.
Both MS highly rely on these amounts that are backfilled to reach the WFD target and may actually not meet
the conditions laid down in EU legislation. In this specific case of Poland, even though a good CDW data
quality was identified through the statistical tests and the analysis of their methodology, it does not guarantee
that backfilling data are correct (see sections 2.3.2. and 2.6.2).
However, the current backfilling figures seem to be underestimated in Eurostat statistics, although it is not
clear to what extent recovery and disposal figures are overestimated or underestimated at the European
level.
Overall, it seems that backfilling is not yet understood and/or reported in the same way by all MS, partly
because some countries do not have a specific code for backfilling operations. The introduction of a specific
R code for backfilling in the Waste Framework Directive would therefore be very helpful.
3.3.4. End of Waste (EoW) criteria
Only five countries (Austria, Belgium, France, The Netherlands and the United Kingdom) have end-of-waste
criteria in place in national legislation mainly for recycled aggregates, other than the EoW criteria set at the
European level (iron, steel, aluminium scrap, glass cullet, copper scrap). In these five countries, it appears
that waste that ceases to be waste (EoW criteria) are still included in the Eurostat statistics. Indeed, EoW
criteria do not seem to affect the CDW data quality as such, as waste ceased to be a waste at a certain step
of the supply chain, and so it is accounted for in the data. EoW criteria might however have an impact on the
statistical measurement of waste, i.e. the correct attribution of the final treatment of such a waste and at
which stage the waste stream should be measured. It means that the introduction of EoW criteria might
change the final treatment that should be included in the statistics reported i.e. it might in fact become a pre-
treatment operation that should be included in the statistics. The reporting methodology proposed by
Eurostat could provide further guidance to MS to help them with this correct attribution. A Workshop between
national statistical offices to exchange their practices related to EoW criteria could as well be an interesting
option.
3.3.5. On-site recycled waste
It is worth noting that in some cases, crushed aggregates from mobile crushers are directly recycled on site,
and are therefore never reported as waste, neither generated nor treated.
This is in line with the recommendations of the Waste Statistics Regulation ((EC) No 2150/2002 (or also
referred to as WStatR) that specifies that on-site recycled waste is excluded from reporting on waste
generation and waste treatment.
Countries wishing to include these on-site recycled aggregates in their recovery targets are free to do so as
the WFD does not specify whether on-site recycled waste should be considered in the recovery rate
calculation.
Up to now, countries do not report such on-site recycled waste in their recovery targets as the quantities are
very difficult to track. If they wish to do so, they should report these waste in both generation and treatment
figures and mention in the quality report the quantities coming from on-site recycling. This would allow
comparing these data with data reported to Eurostat.
3.3.6. Hazardous Waste
For hazardous CDW, while a series of the EU MS show abnormally low (or even null) values, only few
countries display abnormally high values as compared to the median in the EU. As far as hazardous waste is
concerned, the main issues concern hazardous glass waste (W071), asbestos (W12B) and to a lower extent
hazardous mineral waste (W121):
 The absence of reported amounts of hazardous glass waste (W071) in most of EU Member States,
as a result of miscoding issues due to the fuzzy distinction between this CDW category and
hazardous mineral CDW (W121). Actually, Germany and Spain are the only two countries that
report non-null values of generated hazardous glass waste (W071).
 Some MS (i.e. Bulgaria, Ireland, Romania and Sweden) are likely not collecting asbestos (W12B)
separately from other mineral CDW. In this case, asbestos may be mixed with hazardous or even
non-hazardous mineral waste. Hence, these MS should pay particular attention to distinguish
between these waste types in the future to avoid underestimation of this hazardous waste type. In
Croatia, large amounts of waste containing asbestos were collected and reported in 2012. In this
case, the seemingly too high amounts of asbestos does not reflects a misreporting but an
improvement of the practices in dealing with and reporting this waste type.
 Cyprus, Greece and Malta reported abnormally low or even null values of hazardous mineral CDW
(W121). This low amount of declared hazardous CDW could be explained by local specificities,
partly due to the hot climate impacting the construction practices in these Member States. Indeed,
the vast majority of structures in Malta were and still are constructed from limestone and concrete
with minimal insulation materials given Malta’s climatic conditions. In this context, the presence of
dangerous substances in wastes generated from construction and demolition activities is expected to
be lower than in other MS. However, these low values could also be due to underreporting. This
assumption is to be used with caution.
Related to the entire EU (28 MS), only 8 MS (i.e. less than 30 %) are not characterised by null or low
values regarding hazardous CDW. These few member states have high quality CDW data. This supports
the need to consider the few countries with high values as “normal” (good data quality) while the 20 member
states with low amounts of reported hazardous CDW more than probably have problems regarding the
collection and management of hazardous CDW.
Based on this study, it seems that most MS would benefit from more guidance on how to report their
hazardous CDW data more correctly (allocation to the right waste code, sharing practices regarding surveys
and systems for reporting, etc.). More specifically, a particular attention should be paid to hazardous glass
waste (W071) and asbestos (W12B). For these two waste streams, the issue is to make sure that no
possible interpretation could be done, which would allow members states to report these waste types either
as mineral CDW (W121), or as non-hazardous wastes. To that aim, the EU should communicate on the
feasability to correctly estimate these waste types, sharing the good practices of other member states
characterised by good quality hazardous CDW data.
4. CDW management practices in
the MS
This section investigates the underlying reasons which lead to increased CDW recovery rates and to identify
the management practices put forward by MS in order to achieve such high and resource efficient use of
CDW.
4.1. Member States practices: main legislative, regulatory and structural

differences observed
This section highlights the regulatory framework, legal obligations, as well as non-legal initiatives and other
management practices observed in the 28 EU MS.
4.1.1. Legal and regulatory framework – Different levels of maturity across the EU
 General information on the national legislations

Different levels of maturity40, scope and level of implementation are observed in different MS. Some
MS have a long standing legislation concerning waste management issues, already established in the 70s
(e.g. Germany, France, Netherlands, Belgium) and the waste management sector is regulated
satisfactorily throughout the decades. However, most MS have recently applied specific legislation on
waste management. These legislative provisions are at various stages of their implementation. The level of
maturity of MS with regards to CDW management is further assessed in section 4.3 of this report.
All EU MS have successfully transposed the Waste Framework Directive (2008/98/EC) into national
legislation and therefore there is a common basis across EU-28 which defines the principles of waste
management, according to the waste hierarchy. However, in reality the level of implementation of the
several provisions in the WFD is extremely diverse among MS. For example, waste legislation in the
Netherlands was already more advanced by the time the WFD was adopted and waste management
provisions were already anticipated in the country. On the other hand, several MS which have only recently
adopted the principles of the WFD still struggle to align their national waste management performance to the
goals of the European Directive. As a result, the observed differences in the CDW recovery targets was to be
expected.
Specific legislation targeting CDW management is a recent phenomenon, with more and more MS
adopting legislation specifying CDW management practices, while some of the best performers in EU-28 do
not have any national legislation in place, specifically targeting the C&D waste stream. There are however
several rules at local or regional levels which apply to CDW management and these rules have the most
significant effect in driving the increase in recovery of CDW. For example, in Germany, every federal state
has its own rules for CDW management while in Denmark and Estonia, the CDW management planning
responsibility lies with the municipalities.
MS with decentralised government systems can lack the appropriately harmonised national
legislation on CDW management to drive the performance of the country with regional performance varying
dependant on the policies in place; this is particularly the case for Spain. Each region within a MS is entitled
to come up with its own rules and local legislation for sustainable CDW management, which can be viewed
40
Levels of maturity were defined according to four criteria: period of application of relevant legislation (number of years since the
legislation is in place); level of specificity of legislation (general overarching legislation on waste management vs. targeted legislation on
CDW management); level of implementation of the existing legislation (effective application vs. infringement); forward-looking elements
(draft proposals for new legislation, new WMP in place, etc.).
as an opportunity to meet local conditions (e.g. in Brussels there are no landfills, so there is a focus on waste
prevention) and be more flexible than national governments e.g. Basque Country and Catalonia in Spain
have greater requirements compared to nationally. This is very prominent in MS containing many
autonomous governments or regions, e.g. Germany, Italy, Spain, the UK, and Belgium.
However, a very interesting pattern in legislation observed across EU-28 is that MS with the highest CDW
recovery performances do not have specific national legislation on CDW management in place, but good
performance is achieved by a combination of several measures, including general waste legislation,
Waste Management Plan (WMP) and non-legislative CDW initiatives.
Taking Austria (high recovery rate) and Greece (low recovery rate) as examples, it is observed that although
Austria has only one piece of legislation specifically referring to the sorting of CDW, the overall performance
is high, while in Greece a very specific piece of legislation exists detailing the proper CDW management
along the value chain of construction (and demolition), but the effectiveness of this legislation is practically
non-existent (to date) mainly due to the persistence of illegal CDW disposal. As a direct conclusion, the
establishment of a robust legislative framework is not always enough to drive the CDW management
towards a resource efficient direction.
 National planification
As a direct result of the WFD comes the obligation for MS to draw up Waste Management Plans (WMP) and
Waste Prevention Programmes (WPP). Several MS already have long standing WMP before the application
of the WFD, however, updated rules and provisions in the WFD obliged all MS to revise their WMP in order
to be compliant. In MS where the legal framework acts as an overarching policy document for the
management of waste, the WMP is the main source of practical implementation of the waste policy, detailing
the management of each waste stream. These planification documents give guidelines and set
objectives on a shorter term basis than the national laws. A diagnosis of the initial situation shall be
performed prior to establishing such plan and regular updates as well as assessments shall be undertaken in
order to define management practices in line with the current challenges. It is a key tool to ensure an
efficient CDW management, promoting constant progress.
As of March 2015, 22 MS had prepared a WPP and in the vast majority of them CDW is included as a
specific chapter including provisions and measures for reducing the amount of this waste stream (exceptions
include Latvia and Portugal).
The focus below recalls the main provisions defined by the WFD on this topic as well as examples of
implementation of these provisions in a selection of MS.
Focus on WMP and WPP obligations defined in the WFD and examples of applications
Chapter V of the WFD and more specifically articles 28, 29 and 30 of the Directive define the following
obligations:
 MS shall ensure that their competent authorities establish waste management plans that shall:
o set out an analysis of the current waste management situation in the geographical entity
concerned, as well as the measures to be taken to improve environmentally sound preparing
for re-use, recycling, recovery and disposal of waste and an evaluation of how the plan will
support the implementation of the objectives and provisions of the Directive;
o contain, as appropriate and taking into account the geographical level and coverage of the
planning area;
o conform to the waste planning requirements laid down in Article 14 of Directive 94/62/EC and
the strategy for the implementation of the reduction of biodegradable waste going to landfills,
referred to in Article 5 of Directive 1999/31/EC.
 MS shall establish waste prevention programmes not later than 12 December 2013 that shall:
o be integrated either into the waste management plans or into other environmental policy
programmes, as appropriate, or shall function as separate programmes;
o set out the waste prevention objectives: MS shall describe the existing prevention measures
and evaluate the usefulness of undertaken measures. The aim of such objectives and
measures shall be to break the link between economic growth and the environmental
impacts associated with the generation of waste;
o define appropriate specific qualitative or quantitative benchmarks for waste prevention
measures adopted in order to monitor and assess the progress of the measures and may
determine specific qualitative or quantitative targets and indicators;
 MS shall ensure that the waste management plans and waste prevention programmes are
evaluated at least every sixth year and revised as appropriate.
Austria and the Netherlands have defined very extensive and inclusive waste management plans
which, although not legally binding, are followed very closely for the effective implementation of CDW
management. In Italy, according to the legislation, every region must draw up a separate WMP, as no
centralised WMP exists. Similarly in Spain, the Autonomous Communities are drawing up WMP which
can be even more advanced and far reaching than the national WMP (e.g. in Catalonia, Basque
Country – more details available in section 5 on Regional differences analysis). Most MS have updated
their WMP covering the period 2014-2020, while only a few have not updated their WMP despite being
quite old and outdated (e.g. Cyprus).
Discussions with the European Environmental Agency (EEA) suggest that there is little focus on CDW in
national waste prevention plans, and there is a tendency to confuse or merge with recycling. With this in
mind, the EEA is planning to undertake a detailed review of the national waste prevention programmes with
a focus on CDW in 2018. It should also be noticed that in most MS first Waste Prevention Plans have been
adopted in 2012/2014: experience is thus still lacking.
 National targets
Finally, as part of legislation or part of WMP all MS have incorporated targets for the recovery of CDW.
Most MS have incorporated the WFD target – 70% – into national legislation and are required to meet this
target by 2020. Few MS have introduced more ambitious targets, especially MS which have already
achieved high levels of CDW recovery and have exceeded the threshold of 70% of the WFD target. Also,
some regional targets are far more ambitious than the 70% target of the WFD. Examples are given in the
focus below.
Focus on recovery and prevention targets
Recovery target by 2020  Germany: 85%

higher than 70% (including  Estonia: 75%
backfilling)  Netherlands: stabilising the current recovery target (above 90%)
 Wales (UK): 90%
 Flanders (Belgium): 85%
Waste prevention targets  The region of Wales in the UK has defined such targets in its
construction and demolition sector plan. This plan, written by the
Welsh Assembly Government in 2012, considers both
management and prevention of CDW. The following targets are
defined on waste prevention:
o By 2050, waste raisings are to be reduced by around 1.5 per
cent (2007 baseline) each year across all sectors;
o The annual waste prevention target is of 1.4% (based in a
2006/07 baseline) for the construction and demolition waste
managed off site;
 The Swedish Waste Prevention plan 2014-2017 includes the
following targets applied: in 2020 waste generation per m2 built is
decreased compared to 2014 and also the content of hazardous
substances in materials and products shall be reduced.
The implementation, within the national or regional legislation framework, of such ambitious targets
illustrates the determination of a selection of MS in the potential for recovery for CDW. However, such
targets should be defined together with a clear prioritisation of treatment options to ensure sustainable
management of CDW.
Concluding the discussion concerning the legislative framework in EU-28 MS, a preliminary distinction of the
different MS in relation to the maturity of their legal framework is presented in Figure 28. The categorisation
is based on the information retrieved during the screening phase from the 28 MS factsheets. The legal
framework refers to all the relevant legislation in place in the MS which leads to sustainable and resource
efficient waste management with specific focus on CDW. The criteria on which the categorisation is based
are the following:
 Period of application of relevant legislation (number of years since the legislation is in place);
 Level of specificity of legislation (general overarching legislation on waste management vs. targeted
legislation on CDW management);
 Level of implementation of the existing legislation (effective application vs. infringement);
 Forward-looking elements (draft proposals for new legislation, new WMP in place, etc.).
Figure 28: Level of maturity of legal framework in MS
4.1.2. Enforcement of legislation – A logical impact on CDW recovery

performance
 Enforcement of legislation
Legislation defines the requirements for compliance, whereas enforcement monitors compliance and takes
steps to educate and/or penalise individuals and organisations which do not comply with the requirements,
as set out for each MS. Therefore, the enforcement of legislation is very important to achieving the objectives
of each regulatory instrument. Most MS have clearly defined responsibilities for CDW legislation
enforcement, often relying on local authorities in charge of inspections related to environmental legislations.
Sanctions are usually applied to illegal practices, where they are uncovered, and there were a number of
examples in country reports on steps taken to engage the public in assisting the enforcement authorities in
highlighting possible incidences of non-compliance, typically illegal dumping hotlines, such as those
established in Latvia, Portugal and Slovakia. However, a lack of technical and human capacity is often
pointed out by the interviewed stakeholders. As a matter of fact, even though responsibilities and sanctions
are well defined, it is hard to assess the effectiveness of these frameworks. Moreover, some MS appear to
have undertaken important actions to tackle the issue of illegal landfilling but are still underperforming (in
Croatia, some investigations were in progress in 2015 ; in Slovakia more than 700 inspections were
performed in 2014 – see details in the focus below). The focus below presents some illustrations of such
frameworks implemented by MS. These examples show that it is hard to link the existence of these
frameworks with national performance. It also points out that illegal landfilling of CDW is widely practiced
despite legal frameworks and enforcement measures, mainly due to the poor value of these waste
streams.
Focus on national enforcement measures, especially on illegal landfilling
Austria, which is a well performing country, has defined a specific penalty to ensure CDW recovery:
the law for Remediation of Contaminated Sites (Altlastensanierungsgesetz (ALSAG)) states that every
ton of CDW that is not recovered in proper and structurally engineered way is charged 9.20 EUR. This
law is controlled by the fiscal authorities and enforced by customs. However, if CDW is backfilled
according to the law, the responsible person is exempt from a monetary contribution per ton.
However, in Belgium, which is also a well performing country, even though regional and local
authorities are in charge of law enforcement, the lack of capacity is clearly pointed out by
stakeholders.
In Bulgaria, which is a low performing country, responsibilities are clearly defined at each level: the
mayor organises and controls closure, reclamation, and subsequent monitoring of landfills for
household and construction waste on the territory of the Municipalities, the Director of the Regional
Inspectorate of Environment and Water (RIEW), or another appointed authorised person, is in charge
of controlling compliance with the requirements for the waste treatment and the conditions of the
permits. If cases of non-compliance are notified without any measures undertaken to correct them,
penalties can be given with fines scaled according to the gravity of the violation. However, according
to experts, the penalties are not high enough to really discourage the illegal practices as a proper
waste management is perceived as being more costly.
Croatia, which is quite far from reaching the WFD target, has defined responsibilities at national level
with appointed inspectors. Some measures are being taken to address the issue of illegal landfilling.
For example, regarding the illegal landfill Pobrežje near Dubrovnik, the Ministry of Environmental and
Nature Protection is initiating an investigation to determine the owner of the landfill. Recently, concrete
blocks have been placed at the landfill entrance, and a video surveillance system is going to be
installed soon. Again, the lack of inspectors is pointed out as an important issue by the stakeholders.
In Slovakia, where illegal landfilling is also a major issue, the Slovak Environment Agency performs
regular inspections to ensure compliance with legislation. From 718 inspections in 2014 regarding
waste management activities, 193 cases were found non-compliant. There is also an interesting
initiative for individuals to report illegal dumping and fly-tipping to the municipality. As a result of this, a
report in SME states that 109 illegal dump sites in the area of Bardejov were discovered, many of
these contained construction waste, including asbestos.
 Impact of the legislation and the level of enforcement on CDW recovery performance
There may be several reasons for the different levels of performance in the MS such as the existence of
landfill tax and landfill bans, the availability of facilities and the level of enforcement. These are summarised
in Table 8 for three MS with high recovery levels. This indicates that those countries that have landfill tax and
bans in place and an effective enforcement practice tend to have a higher rate of recovery of CDW.
However, this trend is not clear as for these countries which are quite small and dense there may not be that
much space for illegal landfilling in any case.
Table 11: Summary of factors influencing CDW management
MS Recovery rate in Landfill tax in Landfill ban in Availability Effectiveness

2012 (including place place of facilities of enforcement
backfilling) agencies
Netherlands 95% Yes Yes Good Good
Luxembourg 89% Yes No Unknown Good
Belgium 95% Yes Yes (in Wallonia Good Good

and Flanders)
4.1.3. Regulatory and other non-legislative requirements / practices – Different

tools helping MS in their CDW management
Several management practices were identified throughout the MS, but only a few were encountered in all
MS. In an effort to concentrate the management practices that would most likely create favourable conditions
for sustainable management of CDW, a table was developed for all MS factsheets with 5 relevant practices
arising from legal/regulatory obligations in each MS. Figure 29 summarises the findings. The correlation
between measures that create a favourable framework for better CDW management and the actual
performance in a given MS is not as strong as expected: this can be due to a number of factors. In particular,
low enforcement of regulations weakens this link. However, effects of regulations may be only fully visible
some years later.
Pre-demolition audits
Pre-demolition audits are an important driver for recycling: this
preliminary step provides all the stakeholders involved in the
decommissioning, deconstruction and demolition process with
important information on the existing building. Opportunities for
reusing and recycling may then be identified and assessed based
on specific details given on the quantities and accessibility of
building materials. This type of legislation has usually been in
place for 5-10 years.
17 countries41 have introduced them in their legislation. However,

for some of these countries, there is a limited application
(voluntary – mentioned in the waste management plan, regulated
regionally or limited to hazardous wastes).
Application in 17 Member States
- wide application:
AT, BE (Flanders), BG, CZ, FI, FR, HU, IE, IT, LU, MT,
PL, SL, ES, SE, NL, UK
National/regional sorting obligation

(on-site or in sorting facility)
Sorting obligations consist in ensuring the separation of different
waste streams but may not be necessarily applied on-site and
during the demolition process. Waste may be collected as mixed
waste and sorted in a sorting facility. However, this legal
obligation is often not enforced.
Application in 17 Member States
- wide application:
AT, BE, BG, CZ, DE, DK, EE, EL, ES,
FI, HU, LV, LU, PT, SK, SE, UK
41
A study assigned by DG Grow with regard to the Development of specific tools and/or guidelines for assessment of
construction and demolition waste streams prior to demolition or renovation of buildings and infrastructures didn’t confirm
the requirement of such audits in Malta, Poland and Slovenia. This study also mentioned that Romania may have
introduced this obligation but the information was not confirmed.

Resource Efficient Use of Mixed Wastes Improving management-KH0517212ENN (001-058) PDF

Uploaded by

Document Information

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

Resource Efficient Use of Mixed Wastes Improving management-KH0517212ENN (001-058) PDF

Uploaded by

Copyright:

Available Formats

Resource Efficient Use of Mixed

Resource Efficient Use of Mixed Wastes

More information on the European Union is available on the Internet (http://www.europa.eu).

Luxembourg: Publications Office of the European Union, 2017

PDF ISBN 978-92-79-76478-3 doi:10.2779/99903 KH-05-17-212-EN-N

© European Union, 2017

2. CDW MANAGEMENT PERFORMANCE IN EU-28 MEMBER STATES _________________________________ 11

3. PLAUSIBILITY OF OFFICIAL CDW STATISTICS ________________________________________________ 39

4. CDW MANAGEMENT PRACTICES IN THE MS _________________________________________________ 47

5. REGIONAL DIFFERENCES IN CDW MANAGEMENT PERFORMANCE FOR SELECTED MS ___________________ 81

6. RECOMMENDATIONS FOR IMPROVING CDW MANAGEMENT IN MS ________________________________ 100

8. APPENDICES ______________________________________________________________________ 135

Figure 1: Diversity of CDW per activity

1.2. Objectives of the study

1.3. Presentation and methodology of the different tasks

1.3.1. Task 1: Diagnosis of the situation as regards CDW management in EU

1.3.2. Task 2: Case studies

1.3.3. Task 3: Identification of good practices

1.3.4. Task 4: Assessment of the reliability of CDW statistics

1.3.5. Task 5: Preparation and organisation of a workshop

1.4. Structure of this report

2.1.1. CDW classification in EU statistics

2.2. CDW generation performance

2.2.1. Key performance indicators – CDW generation tends to be related to the

Inert waste (Mt) 315

As can be seen, inert waste represents 90% of total generated CDW.

Figure 2: Mtonnes of CDW generated, 2012

200 Average, 164

Figure 3: Tonnes of waste generated/€Million turnover, 2012

Key Performance Indicator Top 5 MS (most waste) Bottom 5 MS (least waste)

CDW/€Million turnover Germany, Hungary, Netherlands, Slovenia, Portugal, Croatia, Slovakia,

CDW/person Netherlands, Luxembourg, Croatia, Slovenia, Portugal, Slovakia,

CDW/GDP Netherlands, Hungary, Germany, Slovenia, Portugal, Slovakia, Croatia,

2.2.2. Nature of CDW generated – A major fraction of mineral waste

Figure 4: Breakdown of total generated waste in 2012

80% 17 08, Gypsum-based construction

60% 17 06, Insulation materials and

10% 17 02, Wood, glass and plastic

Figure 5: Breakdown of CDW generated by material type

2.3. CDW treatment performance, distance to 2020 target and forecasts

2.3.1. CDW treatment performance – A relative importance of recovery compared

Figure 6: Total CDW treated as % total CDW generated

Figure 7: Waste management summary

Figure 10: Proportion of national aggregate demand met by recycled aggregate

2010 2011 2012

2.3.3. Forecasts – An analysis that depends widely on the inclusion of backfilling

Overall waste flow - Thousand tonnes

Recycling - baseline Landfilling - baseline

2.4. Focus on hazardous waste

2.4.1. Hazardous waste generation – CDW, a major share in hazardous waste

Figure 15: Hazardous CDW generated per €Million turnover, 2012

100 Average, 97.5

% non-hazardous CDW % hazardous CDW Average % non-hazardous CDW

Figure 16: Breakdown of CDW generated, 2012

Figure 17: Breakdown of hazardous waste generated in 2012

100% Average, 0.98

Non-hazardous waste Hazardous waste Average % non-hazardous

Figure 18: Breakdown of treated waste

Figure 20: % Hazardous CDW recovered

2.5. Focus on backfilling

2.5.1. Definition of “backfilling” – A Eurostat guidance that tends to clarify the

2.5.2. Potential modification of the definition of “backfilling” introduced by the

2.5.3. Inclusion of backfilling in the EU 2020 target – A disputable statement